Anti-Bribery & Anti-Corruption Policy

1. ABOUT THIS POLICY

Chameleon Pharma Consulting (CPC) is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented. CPC has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever we operate.

If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct.

2. WHO MUST COMPLY WITH THIS POLICY?

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels (whether temporary, fixed-term, or permanent), consultants, interns, volunteers, agents, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located.

3. WHAT IS BRIBERY?

Bribery means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust, or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract, or any other advantage or benefit.

Bribery includes offering, promising, giving, accepting or seeking a bribe.

Specifically, you must not:

  1. give or offer any payment, gift, hospitality or another benefit in the expectation that a business advantage will be received in return, or to reward any business received;
  2. accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else; or
  3. give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure;
  4. threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

4. GIFTS AND HOSPITALITY

This policy does not prohibit the giving or accepting of normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of reasonable gifts and appropriate hospitality is for legitimate purposes such as building relationships and maintaining CPC’s image or reputation.

A gift or hospitality will not be appropriate if it is unduly lavish or extravagant or could be seen as an inducement or reward for any preferential treatment. Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in the name of CPC – not the employee’s name.

CPC recognizes that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.

5. RECORD-KEEPING

CPC will keep detailed and accurate financial records and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.

6. HOW TO RAISE A CONCERN

If you suspect that there is an instance of bribery or corrupt activities occurring in relation to CPC, you are encouraged to raise your concerns at as early a stage as possible. If you are uncertain about whether a certain action or behavior can be considered bribery or corruption, you should speak to your line manager.

CPC will familiarize all employees with its whistleblowing procedures so employees can vocalize their concerns swiftly and confidentially.

Chameleon Pharma Consulting
A Mammut Pharma GmbH Business Unit
Am Tempelhofer Berg 6
10965 Berlin
Germany