EMD SERONO, INC. CODE OF BUSINESS CONDUCT
SUMMARY FOR GRANT RECIPIENTS
The primary objective of EMD Serono's grant programs is the enhancement of physician and patient education and patient care. As a program sponsor, you play a key role in upholding the objectives and standards of EMD Serono's grant programs. This summary presents important elements of EMD Serono's Code of Business Conduct and educational grant policies that govern the conduct of EMD Serono's employees. A complete copy of the Code of Business Conduct and other information about EMD Serono's Compliance Program is available at www.emdserono.com.
EMD SERONO'S COMMITMENT TO INTEGRITY
EMD Serono is dedicated to delivering innovative products that fight debilitating diseases and improve the lives of patients. Our commitment to integrity in everything we do is fundamental to achieving this vision. To achieve our objectives, we apply the highest legal and ethical standards to all of our business activities. EMD Serono will comply with all applicable laws and expects all employees to do the same. No employee may violate the law on behalf of EMD Serono or direct anyone else to do so.
EMD SERONO'S CODE OF BUSINESS CONDUCT
To demonstrate our commitment to integrity and to explain the important laws and policies that apply to our business, EMD Serono has prepared a Code of Business Conduct ("the Code"). The Code summarizes laws and policies that affect how we work at EMD Serono and explains how to get help when needed. Anyone who has a question about the Code, or about any other compliance matter, can contact EMD Serono's Compliance Officer or EMD Serono's 24-hour, toll-free, confidential Compliance Helpline (877-846-8839). The Compliance Officer can also be reached by email at firstname.lastname@example.org or in writing at Compliance Officer, One Technology Place, Rockland, MA 02370. EMD Serono employees who suspect that a violation of law, company policy, or the Code may have occurred are obligated to report it.
GIFTS AND ENTERTAINMENT
To avoid the appearance of improper influence, EMD Serono employees are instructed to use caution in accepting gifts, favors, or entertainment from vendors and customers. To avoid the appearance of improper influence, EMD Serono employees cannot ask for a gift or favor; accept a gift or favor if it could reasonably appear that the giver is seeking to influence an action or decision by EMD Serono; or accept a gift of cash or its equivalent.
HEALTHCARE LAWS AND REGULATIONS
EMD Serono employees are required to comply with all laws relating to the conduct of business in the pharmaceutical and biotech industries, including the Anti-Kickback Statute, the False Claims Act, the Food, Drug and Cosmetic Act and the Prescription Drug Marketing Act. To maintain the integrity of our relationships with providers and to help EMD Serono employees abide by the laws and regulations, EMD Serono has voluntarily adopted the PhRMA Code on Interactions with Healthcare Professionals, a set of industry guidelines governing relationships between pharmaceutical firms and physicians.
EDUCATIONAL GRANTS POLICY
EMD Serono believes that dissemination of scientific and educational information is a worthy undertaking deserving of support. Educational grants must comply with EMD Serono's grant submission and approval procedures, which require that grant requests be submitted to EMD Serono in writing in advance of the event, and that all requests include detailed information concerning the activity to be supported (including a budget showing how the funds will be used). In awarding a grant, no preference is given as a reward or in exchange for prescribing or purchasing EMD Serono products or to induce the prescription or purchase of EMD Serono products in the future. Grant recipients are not expected or obliged to prescribe, purchase, or recommend any EMD Serono product. Additional requirements concerning the use of educational funding are set forth in the grant agreement that must be signed in connection with any grant award.
CONFLICTS OF INTEREST
EMD Serono employees have an obligation to act in the Company's best interest and act with integrity. EMD Serono employees are instructed to avoid conflicts of interest, where outside activities or personal interests may jeopardize the individual's ability to make objective decisions in the course of doing his or her job.