Summit Pharmaceuticals Europe S.r.l. (thereafter as SPE) is part of Sumitomo Corporation, a leading Japanese trading company founded in 1919. The Group represents itself as a global organization that strives to stay one step ahead, anticipating change and contributing to the well-being of society.
SPE has taken the initiative to craft this comprehensive Code of Ethics, outlining the steadfast ethical principles that guide the company’s decision-making process daily.
The Code of Ethics should be effectively communicated to all stakeholders engaged in business interactions with the company, fostering a culture of responsible conduct that aligns with the organization’s values, principles, and overarching commitment to maintaining a robust compliance framework.
The company places a strong emphasis on its employees’ awareness and adherence to its core values, expecting them to embrace and uphold these values while actively contributing to the company’s growth and development in alignment with its guiding principles.
SPE’s commitment, as outlined in its Code of Ethics, encompasses the following key objectives:
o Cultivating a reputable market image by adhering to steadfast principles that foster sustainable growth.
o Ensuring customer satisfaction by consistently operating in full compliance with prevailing laws and regulations.
o Nurturing the continuous and long-term professional advancement of its employees within the organization, fostering an environment conducive to their growth and development. Summit Pharmaceuticals Europe has adopted the activity guidelines developed by Sumitomo Corporation and is committed to operating in accordance with them. This document and the activity guidelines, set out below, show full alignment between SPE and the Head of the Group.
o Acting with utmost honesty and sincerity in line with Sumitomo’s business philosophy and Management Principles. This includes promoting respect for the physical, moral, and cultural integrity of individuals, while creating a safe working environment that upholds their dignity.
o Ensuring strict compliance with laws and regulations while upholding the highest ethical standards.
o Placing great value on transparency and openness, rejecting all forms of discrimination based on gender, sexual orientation, age, race, religion, political and/or trade union affiliation, language, origin, or abilities. Discriminatory speech or actions, harassment, bullying, slander, defamation, threats, violence, or any behavior that causes discomfort to others is strictly prohibited. Instead, the organization cherishes each employee indiscriminately, fostering professional growth, continuous dialogue, and well-being within the workplace.
o Prioritizing the protection of the global environment as a matter of great importance.
o Contributing to society as a responsible corporate citizen.
o Promoting teamwork and integrated corporate strength through active communication.
o Setting clear objectives and pursuing them with unwavering enthusiasm
The Code of Ethics is made available in English to all interested parties through a special section on the Website (www.summitpharmaeurope.com). This document may be subject to periodic revision, to keep it in line with the provisions of the Law and regulations.
The company is fully dedicated to ensuring the widespread distribution and understanding of this document, emphasizing the importance of all recipients being familiar with and upholding its contents, principles, and code of conduct.
This obligation is addressed to directors, employees, collaborators, suppliers, distributors, and consultants who in any capacity operate permanently or temporarily in the interest of SPE.
The objective is to contribute to the sustainable growth of the company through the sharing of strong business ethical values, including good faith in conducting business activities to avoid the possibility of wrongdoing.
COMMITMENT
Anti-bribery and anti-corruption
The company is constantly striving to apply the necessary measures to prevent the improper provision of benefits and bribery of a government or other public official in any country, municipality, or region. The company complies with domestic and foreign anti-corruption laws and regulations.
SPE does not tolerate the offering, giving, or promising of cash or cash equivalents, gifts, entertainment, or anything of value to public officials for the purpose of improperly obtaining or retaining business. Should the company receive a request from a public official, it shall be obliged to refuse the request and contact the competent authorities.
Regarding anti-money laundering, SPE’s directors, employees and collaborators are required to exercise the utmost care when:
o they are asked to receive or make payments to entities that are not part of the transaction in
question.
o the origin of the money is suspicious or untraceable.
o payments are made or received anonymously.
Fair competition
SPE promotes fair competition through its business activities by always complying with antitrust and fair competition laws and regulations. Fair business practices will ensure lasting prosperity, honesty, and integrity in the conduct of business. Valuing trust is also one of the Group’s corporate principles.
Under no circumstances may the company:
o create or participate in improper monopolies.
o enter into rigged bids or other collusive/anticompetitive agreements with competitors.
o abuse a dominant position in the market.
o engage in discussions with its competitors for the purpose of fixing prices or sales volume.
Furthermore, the company must avoid, if possible, taking part in communications that could create the appearance of such improper discussions.
o Entering into an anti-competitive agreement. If it is proposed by a customer, it must be clearly and formally rejected.
Conflict of interests
Conflict of interest is defined as any circumstance that may cast doubt on the ability of directors, managers, and officers, as well as non-management employees, to act objectively in the interests of the company.
All individuals must actively refrain from engaging in any action or displaying any interest that could potentially create a perception of conflict or impropriety. It is imperative that there is an absolute absence of conflict between one’s personal affairs and their responsibilities and obligations within the company.
SPE ensures that it always acts in the best interests of the Sumitomo Corporation Group and never uses company assets or its position within the company to pursue its own interests or those of third parties to the detriment of those of the Group. Every employee has a duty of loyalty to the Group and must endeavor to always act in the Group’s interest. They are not permitted to use their position or role for personal gain. Employees must refrain from engaging in personal activities that may interfere with their work responsibilities.
International trade regulations (trade security controls)
The company firmly upholds the belief that strict adherence to laws, regulations, and international treaties governing imports, exports, trade security, and customs is paramount in conducting business within the market. The trade of illegal products or involvement in commercial transactions that may violate or unlawfully circumvent laws is unequivocally contrary to the core principles of SPE.
It is important to emphasize that SPE has never been involved in such activities and provides a steadfast assurance that it will never engage in any actions that could pose a threat, or even appear to pose a threat, to international peace or security.
Data protection and confidentiality
The company guarantees the strict confidentiality of all information received from other parties. SPE is committed to ensuring that there is no leakage of confidential information that could cause substantial loss, damage, or adverse impact on its business to third parties. Employees must not use material non-public information of a company to buy, sell or cause others to buy or sell publicly traded securities.
The company ensures that no conduct is engaged in that violates, or may give the appearance of violating, insider trading laws and regulations.
Intellectual property
All companies own intellectual property (‘IP’). This includes patents, designs, trademarks, copyrights, trade names and trade secrets.
SPE places utmost importance on upholding and respecting intellectual property rights (IP) throughout all its operations. This includes a commitment to safeguarding the IP rights of both the Group and third parties. Additionally, stringent measures are taken to prevent any infringement upon the intellectual property rights held by others. Diligence and careful attention are exercised to ensure full compliance with IP laws and regulations.
The company and its employees must ensure that there is no infringement of intellectual property rights when deciding to produce or sell a product using new technologies or brands. If any individual becomes aware of a potential infringement upon the company’s intellectual property rights, it is kindly requested to promptly contact the Legal Department.
Fair business and law compliance
SPE recognizes the utmost importance of being well-informed about and adhering to the laws and regulations governing its business operations. As such, it is mandatory for all employees to possess a comprehensive understanding of the laws and regulations relevant to their specific roles.
Furthermore, employees are expected to remain vigilant regarding any changes or new developments in applicable laws, always ensuring continuous compliance with legal requirements.
The organization firmly believes in the importance of and compliance with the laws in all the countries in which it operates, guaranteeing transparency in all its activities; in fact, it extends this commitment to all its collaborators, ensuring that they operate in compliance with the legislation in force.
If needed, SPE’s employees should consult the relevant departments or managers to find out the specific laws of the sector. It is against the spirit of SPE to try to exploit and take advantage of any ambiguities or loopholes in laws or regulations.
Accuracy of company books and records
SPE complies with the law by accurately compiling its books and records in a timely manner and properly storing all related documents. In addition, the company ensures the timely payment of taxes and fulfils its tax return obligations in accordance with applicable laws and regulations.
Ensuring timely access to books, records, and associated information serves as a crucial requirement for SPE. This practice enables the accurate representation of the company’s financial position while safeguarding its valuable assets.
Promoting transparency with stakeholders serves as an additional driving force for SPE.
Consequently, the inclusion of false or misleading information in registered documents is strictly prohibited. The company diligently maintains records that provide an accurate and reliable reflection of recorded transactions, as well as the assets and liabilities held by the organization.
All documents are properly retained for the time required by law.
Human rights
The company recognizes respect for human rights as an indispensable principle. In its management principles, the Sumitomo Corporation Group is committed to “placing the utmost importance on integrity and sound management with the utmost respect for the individual”.
Therefore, it does not tolerate any form of discrimination or harassment regarding race, ethnicity, nationality, origin, color, age, sex, sexual orientation, gender identity, disability, religion, political affiliation, trade union membership, marriage, or any other reason unrelated to their business.
The company maintains a zero-tolerance policy towards discriminatory speech or actions, harassment, bullying, slander, defamation, threats, violence, or any other form of behavior that instills fear or discomfort in others. Such unacceptable conduct is strictly prohibited within the organization.
Everyone is allowed to express themselves freely and professionally without fear of the judgement of others.
Health and safety
SPE is fully dedicated to fostering a safe working environment that prioritizes the physical and mental well-being of its employees, third parties, and business partners. To this end, the company is firmly committed to mitigating risks associated with health and safety by implementing best practices and undertaking all necessary measures to safeguard individuals’ well-being. Any form of unsafe or violent behavior that jeopardizes the health and safety of others is unequivocally condemned by SPE.
Fair employment practices
The company is committed to ensuring the job security of its employees, guaranteeing them equal opportunities for professional development, skills development and encouraging them to always express their opinion.
Furthermore, equal career opportunities are guaranteed for all its employees, without exception.
Respect for the environment
The protection of the environment is an issue of global importance; it is necessary to make effective and efficient use of the planet’s resources, which are limited. Natural ecosystems should also be given the utmost attention and be preserved.
SPE recognizes the imperative of environmental stewardship for achieving sustainable growth. In all its activities, the company remains steadfast in its commitment to safeguarding the environment and preventing any potential harm. Both employees and the organization diligently adhere to applicable legal and regulatory requirements to proactively mitigate any adverse impact on the environment. By upholding these standards, SPE demonstrates its unwavering dedication to environmental protection and preservation.
The company complies with the Sumitomo Corporation Group’s environmental policy, which contains applicable environmental laws and environmental protection agreements. SPE members attach great importance to environmental protection and strive to achieve sustainable development through their business activities.
Product safety and liability
SPE guarantees compliance with all safety standards of the products it sells to its customers, ensuring that they will not pose unreasonable dangers to users or the environment. This is achieved by carefully selecting its suppliers, dealing only with those that are financially, technologically, and ethically sound and responsible.
SPE’s business is to act as an intermediary between the supply and demand of products in the pharmaceutical sector. Therefore, it is essential that the safety of drugs is always guaranteed by the pharmaceutical companies with which SPE has business relationships.
To this end, all companies with which SPE has relations must comply with the laws and industry standards. In this way, the possibility of undesirable effects of any kind that could harm patients’ health can be averted.