By holding ourselves to the highest ethical standards, the Company does not use gifts, meals, hospitality, entertainment, recreation, and other items or activities of value to influence a payer to prescribe, use, purchase, recommend, or make favorable formulary recommendations concerning our products.
Similarly, Employees are not permitted to accept gifts because of the potential, or the appearance of the potential, to unfairly influence a Company decision.
You must avoid activities or relationships that conflict with the Company’s interests or adversely affect the Company’s reputations. The types of activities and relationships you must avoid include, but are not limited to:
- Accepting or soliciting a gift, favor, or service that is intended to, or might appear to, influence the Employee’s decision-making or professional conduct; or
- Giving or offering to give any gift, gratuity, favor, entertainment, reward, “bribe” or “kickback” or any other thing of value that might influence or appear to influence the judgment or conduct of the recipient in the performance of his or her job. This includes transactions with government personnel from any country, customers and suppliers.
You may give or receive unsolicited gifts or entertainment only in cases where the gifts or entertainment are of nominal value, are customary to the industry, will not violate any laws and will not influence or appear to influence the recipient’s judgment or conduct at his or her employer’s business. In the event of the receipt of a gift of unknown value or excessive value where non-acceptance would be detrimental or cause embarrassment, the gift should be deemed Company property and given to the CEO for proper disposition.