Page 8 - Shionogi flipbook NEW

8
Gifts and Entertainment
Appropriate gifts and courtesies help us develop and maintain strong business relationships, but they should never compromise, or appear to compromise, our judgment. We must always use com- mon sense and comply with the law and anti-kickback statutes that apply to our work with HCPs. We may never offer or provide cash, services, gifts, entertainment, meals or any other item of value to an HCP for the purpose of in uencing or rewarding the prescrip- tion, use, referral, or purchase of a Shionogi product.
Con icts of Interest
The decisions we make at work should re ect the best interests of Shionogi. Con icts of interest arise when we have relationships or interests that could interfere with the Company’s objectives. Our reputation as a fair and trust- worthy company depends on us avoiding even the appearance of con icts of interest. We all have a responsibility to recognize and disclose con icts or potential con icts if they arise.
Together, we:
• Avoid interests, activities or relationships that could interfere with our ability to make fair and objective decisions on behalf of Shionogi.
• Never exchange gifts or bene ts with individuals who are hoping to do business with the Company.
• Contact a manager, the Of ce of Business Ethics and Compliance, the Human Resources Department, or the Legal Department if a potential con ict of interest arises.
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Engage in outside employment or consulting work, es- pecially if it involves a competitor or business partner.
Have a family or close personal relationship with someone who wants to work for the Company or do business with the Company.
Hold a nancial interest in a company, especially if that company is a competitor or business partner of Shionogi.
Have a close family member working with a product that directly competes with ours.
TO MAKE IT CLEAR:
Relationships and Activities to Disclose
Keep an eye out for certain situations where con icts are likely to arise. Speak with your manager or a compliance resource if you:
In most cases, we can work with you to resolve the con ict quickly and fairly.
BE MINDFUL:
Reporting Relationships
Any reporting relationship that could compromise your ability to be objective is also a con ict of interest. As a general rule, we should not report to or manage (directly or indirectly) someone who is a family member or close personal friend.