THIS TEMPLATE CODE OF CONDUCT IS FOR DEMONSTRATION PURPOSES ONLY AND SERVES AS EXAMPLE. DISTRIBUTORS ARE NOT REQUIRED TO ADOPT OR USE THIS TEMPLATE WHEN COMPLIANCE REQUIREMENTS AND GOVERNANCE ARE DOCUMENTED DIFFERENTLY.

CODE OF CONDUCT

INSTRUCTIONS

Customize this document according to your company’s and local needs. Add any other relevant matter that is applicable in the country your company operates in or any other references to your intercompany documentation. Ensure this document is accessible to all employees, officers, directors, employees and business partners, such as sub distributors and agents. Train your employees on the Code of Conduct regularly and keep training records. Complete any parts highlighted. You may consider including additional sections on Privacy, Cybersecurity, Environment Protection Charitable Contributions, social media, etc., depending on the requirement in your country.

INTRODUCTION AND SCOPE
Your Company Name is committed to maintaining exemplary corporate conduct and high ethical standards. This Code of Conduct sets forth Your Company Name expectations of, and requirements for all officers, directors, employees and business partners to follow. Where the law imposes a more stringent requirement than this Code of Conduct, [company] will follow the law. Where this Code of Conduct imposes a more stringent requirement than the law, [Company] will apply this Code of Conduct, to the extent that its requirements are consistent with the law. It is the responsibility of every director, officer and employee to understand and comply with the Code of Conduct where the company can introduce its mission and values, and tie them to the code of conduct.
BASIC PRINCIPLES
COMPLIANCE WITH LAWS	Your Company Name conducts its business and affairs in compliance with all applicable laws, rules and regulations. The purpose of this Code of Conduct is to guide Your Company Name’s directors, officers and employees in their work for Your Company Name.
CONFLICTS OF INTEREST	A conflict of interest arises when an individual’s personal interest interferes or could interfere in any way with Your Company Name interests. Examples include, but are not limited to, personal relationships with government officials or health care professionals, and employment with another company. Any actual or potential conflict of interest must be disclosed as soon as it arises.
FAIR DEALING	Your Company Name deals with its suppliers and business partners in a fair and transparent way. We do not take unfair advantage of anyone through manipulation, concealment, abuse of information or misrepresentation of facts, or any other unfair dealing practice. Tenders require a transparent, fair and equal bidding process. Tenders must never be entered with the intent to bribe or otherwise improperly influence a Government Official or HCP.
PROMOTIONAL ACTIVITIES, MARKETING AND SALES	Your Company Name represents its principals’ products and services accurately and complies with applicable regulatory and legal requirements, as well as applicable industry codes, in its promotional activities. Medical technology products must never be marketed in any country where they have not been approved for use.
RECORDING AND REPORTING FINANCIAL INFORMATION	Your Company Name maintains accurate books and records and internal controls in accordance with applicable laws.
ANTI-BRIBERY AND ANTI-CORRUPTION	Your Company Name is committed to observing high standards of ethical business conduct, and compliance with applicable anti-bribery and anti-corruption laws (“ABAC Laws”), and similar laws in other countries where Your Company Name does business. Your Company Name prohibits its employees and third parties from offering, giving, promising and authorizing any bribe, gift, loan, reward, fee, or any other benefit to any government official, customer, healthcare professional, company officer or employee, or any other benefit to another person in order to improperly influence the recipient to misuse his or her official position or to gain an improper business advantage. All Your Company Name third parties must comply with ABAC laws that apply to their business activities in connection with their relationship with Your Company Name.
IMPROPER PAYMENTS	Improper payments mean unlawful or with a corrupt intent. Payments in cash or in kind or in the form of an offer of anything of value to any person, whether or not a government official, with the purpose of obtaining an improper business advantage are considered improper payments and are prohibited. An Improper Payment includes anything that would be of value to the recipient, regardless of its financial value. Improper payments can also be payments of low value intended to expedite or facilitate routine bureaucratic processes.
INTERACTING WITH HEALTH CARE PROFESSIONALS AND GOVERNMENT OFFICIALS	Your Company Name interactions with government officials, healthcare professionals (HCPs) and healthcare organizations (HCOs) must always be professional exchanges with the purpose of improving medical knowledge, patient care or otherwise have a legitimate business purpose. Whenever these interactions involve payments, meals, travel, or any other benefit to an HCP, Your Company Name ensures that the benefits are legal under all applicable laws and regulations, supported by a legitimate and documented business need, and set out in a written agreement. All amounts paid to HCPs must be consistent with fair market value. Where applicable, transfers of value to HCPs must be reported in accordance with transparency reporting obligations.
GIFTS AND ENTERTAINMENT	[Your Company Name] does not offer gifts or entertainment to government officials, HCPs or HCOs. However, we may occasionally offer HCPs and HCOs items that benefit patients or serve a genuine educational function, provided that the value of the items is modest and they are not offered as an improper inducement.
TRADE COMPLIANCE	[Your Company Name] complies with all import and export laws and regulations that apply to [Your Company Name’s] business activities. Those laws and regulations include economic sanctions, export controls, import regulations, customs measures and similar rules. Employees must not take any action in connection with Your Company Name business that would cause Your Company Name to violate trade laws or regulations.
COMPETITION LAW	[Your Company Name] complies with competition laws. This means that we do not agree with competitors to fix prices, allocate markets or customers (including, for example, agreements with competitors as to who will bid at which price in a tender), limit supply, or boycott customers. We do not unilaterally assert our market power as a way to exclude competitors from the market.
COMPLIANCE
REPORTING/SPEAK UP Any violation, or suspected violation, of this Code of Conduct must be reported immediately to [insert relevant person(s)/department(s)]. [If you are concerned about retaliation, you may report anonymously.] [Your Company Name] does not tolerate retaliation against anyone who makes a good faith report of suspected misconduct. If you believe that you have been subjected to retaliation, you should immediately contact [insert relevant person(s)/department(s)].