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The company recognizes the following principles:
PQE Group (including Pharma Quality Europe S.r.l. and the relevant Subsidiaries) is a company that provides consultancy and services, which derives precise ethical, and legal, responsibilities towards corporate customers, institutions and communities in which these companies operate.
As the central value of PQE’s culture and behaviour, the concept of “integrity” is the main importance for all stakeholders (ownership, employees, consultants, customers, suppliers, business partners, etc.).
In order to achieve this goal, PQE is required to continuously operate in a context of unbiased competition, fairness and good faith, while respecting the legitimate interests of all stakeholders, as well as in conformity of the laws of the countries where the sites, and activities, are located. Hence, the need for all individuals involved in working or collaborating with PQE, to adhere to these ethical and behavioural principles and enforce them as part of their duties and responsibilities.
In addition to a pure moral values, this intention takes on the evidence of a strong corporate characterisation and ensures the stability of the context in which PQE has to operate.
The importance of the ethical subject has resulted in PQE’s management clearly defining the values and responsibilities both internally and externally. For this reason this Ethical Code has been developed. It also acts as an Internal Regulation, whose knowledge and compliance by all employees, collaborators and partners become critical factors to the proper internal functioning and the positioning of the company towards its customers.
This document has been prepared to explain the basic elements of our corporate culture, as well as the behavioural standards in the business management and in the implementation of various business activities. As a matter of fact, it constitutes the official document where the Ethical Values, in which PQE identifies itself, are established. PQE also undertakes to respect these values and ensures that the various people / companies with whom it trades (hereinafter identified as subjects addressed) coherently respect them as well. The company therefore requires its employees and collaborators to continuously demonstrate the sense of belonging to the company’s ethics that is expressed through a supportive behaviour towards both the entire group and the employer.Furthermore, the implementation of the code comes from the desire to:
Matters defined by this Code apply to PQE’s entire organization and are binding for all its collaborators (Ownership, Employees and Consultants). All collaborators are required to observe and then, to the extent of their competence, to enforce the principles contained in the Ethical Code and may be subject to penalties for violation of its provisions. For these reasons, all those who establish a relationship with PQE undertake to act in agreement with the provisions of the Code, to consult their manager with respect to any doubts or possible interpretations of some contents of the Code and to report any violations that they are aware of. For the avoidance of doubt, this Ethical Code applies to employees, collaborators and partners of all the entities belonging to the PQE Group.
In perfect alignment with the Universal Declaration of Human Rights, PQE respects the fundamental rights of every individual, protecting the moral integrity and ensuring equal opportunities. Therefore, PQE does not allow any form of isolation, exploitation and/or harassment and discrimination due to personal or work reasons, diversity of race, language, colour, faith or religion, political affiliation, nationality, ethnicity, age, gender, sexual orientation, marital status, inability, disability and/or physical appearance, social and economic condition.
The respect of ethical standards and transparency in the conduct of business are necessary conditions, as well as a competitive advantage, to pursue and achieve the defined company’s goals. PQE therefore bases its actions on respect for basic principles, such as:
PQE engages to provide an impartial action, to avoid preferential treatments as well as disparities in service, to refrain from putting and / or succumb to undue pressures by taking initiatives and decisions with the utmost transparency, avoiding to create or benefit from situations of privilege.
Matters defined by this Code apply to PQE’s entire organization and are binding for all its collaborators (Ownership, Employees and Consultants). All collaborators are required to observe and then, to the extent of their competence, to enforce the principles contained in the Ethical Code and may be subject to penalties for violation of its provisions. For these reasons, all those who establish a relationship with PQE undertake to act in agreement with the provisions of the Code, to consult their manager with respect to any doubts or possible interpretations of some contents of the Code and to report any violations that they are aware of. For the avoidance of doubt, this Ethical Code applies to employees, collaborators and partners of all the entities belonging to the PQE Group.
All subjects addressed in this document are requested to respect the laws and regulations, of the Ethical Code and the company’s internal rules, apply them with honesty and fairness, avoid conflicts of interest between personal, business and customer’s goals.
Health safeguard is an integral part of PQE’s corporate mission since the company includes in its values construction chain relevant for health purposes. For this reason, it discusses these issues with the institutions and the various organizations of the civil society and provides expert advice, along with useful professional contributions for the achievement of goals in the field of life science. The company promotes and supports social, cultural and, where possible, solidarity initiatives, within the sector in which it operates.
PQE evaluates all its employees and collaborators as a primary resource of its work activity, involving them in the company’s business, offering services that improve the life quality and ensuring a working environment based on attention, active listening, trust and professional recognition. The management team informs and shares with the staff the management criteria adopted, making records and documents transparent and accessible. It also protects and safeguards its staff against negative events or external threats, as well as against acts of psychological violence, fighting any discriminatory form or detriment to the person and their ideas. PQE repudiates all forms of sexual harassment, workplace bullying situations and conducts or verbal expressions that may offend the person. In order to ensure this context, PQE promotes working conditions that:
PQE is active in the adoption, compliance and implementation of shared and effective professional behaviour to its own image and the industry in which it operates. The conduct of all individuals during the performance of their assignments or functions has to be inspired by transparency, fairness and mutual respect as well as loyalty, both in the form and in the substance, according to the current regulations and internal procedures, in order to protect the company heritage and image. In particular, following attitudes should be avoided:
Each Subject addressed does not accept, or make, any pressures, recommendations or reports, which could harm PQE or cause undue advantages for himself, PQE or third parties. Each Subject addressed also rejects and does not promise and / or offer money or other undue benefits, unless they are of little value and not related to, or conditioned by, requests of any kind. If the Subject addressed receives from a third party an offer or a request for benefits, excluding gifts of small value, they will immediately inform their manager or, where applicable, the person to whom they should report such evaluations and actions.
PQE guarantees the protection and safety in the different work places for its staff and for third parties, committing itself to comply with current regulations and promoting health and safety of all places that form the work environment, even beyond legal requirements expressed by the Italian Law D.Lgs. 81/2008 and by the health and safety legislations applicable in the countries where PQE employs its personnel.
PQE guarantees the protection of personal data of every employee/collaborator. In the event that the latter is forced to provide sensitive and / or personal information, the company guarantees its treatment in compliance with current regulations.
The chances of employment and / or career advancement resulting, as already mentioned, from the recognition of professional talent and sense of responsibility, from the identification of achievements and competencies expressed, are based on objectivity and transparency criteria, ensuring equal opportunities and avoiding any form of favouritism. PQE’s commitment towards its staff covers both the technical training and the managerial growth. As part of the integration of new employees/collaborators, PQE is sensitive to the inclusion of new graduates and hires its staff exclusively with a regular contract, not tolerating any form of illegal employment or “moonlighting”. PQE ensures the principle of equal opportunities and it operates on this basis for the career advancement and salary increase, comparing them to the market conditions, and ensuring transparency, reliability, accuracy and clarity of its valuation methods. PQE contributes to social development combining the pursuit of economic revenue (and therefore the well-being of its employees), while maintaining strong ethical principles in supplying its services. PQE strongly commits to the creation of new job opportunities, to the care and attention of protected categories and to the support to major social problems.
As a socially responsible company, PQE believes that its success is tied to the well-being of the community and the environment in which it works and lives. PQE therefore commits to protecting the environment and the health and safety of its employees. As part of this commitment, the company complies with the regulations relating to the environment (by implementing, for example, the Legislative Decree 151/2005 of Italian Law on the disposal of electrical and electronic equipments) and it encourages its staff to use its assets with attention, making its staff aware of the proper recycling of waste. PQE in fact seeks to minimize the harmful effects to the environment caused by its activities and to achieve higher goals in relation to the environment. Responsibility for the environment is one of the criteria observed when evaluating and selecting suppliers.
This section details the Rules of Conduct, in order to better identify the behaviour which all individuals who work with PQE must comply with in performing various business activities, while respecting the principles of the Ethical Code.
It is all managers’ responsibility to promote the internal communication through an appropriate management of interpersonal relationships with their resources, being a good example and ensuring opportunities for dialogue and listening, both individual and group. The assumption of responsibility, initiative, spirit of collaboration are inseparable aspects that characterize the activity of each employee/collaborator. On this basis, PQE considers essential the application and sharing of certain behavioural rules in the company by all its staff, related both to interpersonal relationships and to the image. In general, PQE requires the adoption of the principles of “good manners enterprise,” as summarized below. It is forbidden to:
It is required to:
PQE considers it essential to provide transparent, accurate and complete accounting information. For this purpose it endeavours to organise an exact and reliable accounting system, which correctly represents the results of operations and provides the tools to identify, prevent and manage, as far as possible, financial and operational risks, as well as fraud to the company’s or third party’s detriment. The accounting surveys, and the documents that derive from it, must be based on accurate, complete and verifiable information and must reflect the nature of the operation which they relate to, in accordance with the external constraints (laws, accounting principles), as well as policies, plans, regulations and internal procedures The accounting surveys must allow to:
It is necessary to refrain from participating in decision-making, processes or any other activity, which could create conflicts of interest. Those who might learn about a possible conflict of interest, must immediately notify their manager or the company’s management.
PQE considers it essential to provide transparent, accurate and complete accounting information. For this purpose it endeavours to organise an exact and reliable accounting system, which correctly represents the results of operations and provides the tools to identify, prevent and manage, as far as possible, financial and operational risks, as well as fraud to the company’s or third party’s detriment. The accounting surveys, and the documents that derive from it, must be based on accurate, complete and verifiable information and must reflect the nature of the operation which they relate to, in accordance with the external constraints (laws, accounting principles), as well as policies, plans, regulations and internal procedures The accounting surveys must allow to:
All staff is required to respect the infrastructures, equipment, tools and materials of the Company. Individuals should promptly report to the Internal Supervisory, constituted by the Operation Manager and the Human Resources Manager, if there is any different use of equipment. All staff is required to use the company’s facilities only for the performance of work tasks.
For the duration of the contract and for at least six months after the termination of the same, whichever is the cause, the employee/collaborator undertakes not to carry out, either directly or through a third person or entity, activities or transactions on behalf of PQE’s customers and / or companies whose activities can be considered, directly or indirectly, competitive with those carried out by PQE, aware of the exclusivity that their current activities have for PQE, in all areas of expertise.
PQE considers that it is a fundamental and indispensable value to let the company’s image to come out with clarity, fairness and diligence in all communications and in all relations outside the company. It strives to establish fair terms of communication, making it not possible to provide false information, manipulate data on the current status and on the expectations of its customers, avoiding the creation of false evaluations and incorrect expectations. Relations with public institutions, with interest groups, the press and the media and all company’s institutional communications are held exclusively by the responsible in charge of these functions and with the management’s explicit mandate.
The focus of PQE ‘s policy is the customer’s satisfaction and the quality of each relationship. PQE aims to be in active collaboration with its customers and engages in anticipating and responding quickly to the changes of their demands, while preserving a culture that encourages the best of each actor in the relationship. To create and maintain this kind of relationship, PQE’s employees and collaborators undertake to:
If the client is in a non-compliance status as reported by PQE’s employees/collaborators and they decide not to follow the suggested interventions, then it is the employee’s/collaborator’s responsibility to provide a written notification to the client.
Suppliers and partners play a key role in improving the overall competitiveness of the company and in the pursuit of its objectives. All suppliers and partners are guaranteed the compliance with the principles of equal opportunities, fairness and impartiality. Employees and collaborators must select suppliers on the basis of the Ethical Principles of this Code and are encouraged to create and maintain stable, transparent and collaborative relationships with them, acting always in the best interest of the company. Each employee/collaborator must immediately notify their supervisor of any behaviour that seems contrary to the principles expressed in this Code.
The behaviour of Social Authorities and of all PQE’s employees/collaborators with the Public Administration must proceed with the greatest transparency, correctness and integrity and in strict compliance with the regulations applicable in the countries where PQE operates and with the internal rules, procedures and organizational models that PQE may adopt from time to time.
Relations with the press and media are exclusively held by the company’s responsible assigned to this function. All the interventions of external communication must be previously authorized by the company’s management.
PQE’s employees must avoid negative comments and judgments towards its competitors. Negative comments about competitors and their services are considered counter-productive and inappropriate. The only way for promotion / marketing of its products / services is illustrating their value and quality, without demeaning the competitors’ offer. If a Customer requests a comparison with a competitor’s services, it is permitted to highlight the benefits of PQE’s own services, making sure, however, that any comparison meets the equity and fairness criteria provided by this Code. PQE recognizes that a fair, free and loyal competition is a decisive factor for the growth and the continuous improvement of the company.
Information and training on the Ethical Code and its content is a crucial aspect for the organization and among its objectives, it has the promotion and the strengthening of corporate culture on the recognized values, as well as the disclosure of rules, procedures and practices to be followed and, especially, the extension of the approval to the mission and principles declared. For this purpose, PQE is committed to establishing and implementing appropriate internal communications and training / information plans for all employees/collaborators. The verification and monitoring of the actual compliance with this Ethical Code is delegated to the internal Supervisory Board, formed by the Operation Manager and the Human Resources Manager, who have been assigned the following responsibilities:
To offer the Code the necessary visibility and awareness, PQE prepares meetings and seminars. The document is also available in an electronic format on the company’s intranet / local network, together with the various procedures and the Organisation, Management and Control Model. In case of new employment contracts or other agreements, they must contain an explicit reference to the current Ethical Code. Similarly, communication plans to disclose its contents outside the company will be activated and standardized. Reference is made, however, to the Organisation, Management and Control Model for the identification of suitable tools and internal control measures.
Any employee of PQE who is aware (or believes in good faith) that a provision of this Code has been violated or has concerns about any matters addressed in this Code or about its application is encouraged to report the relevant circumstances to his/her manager, or to the Quality Assurance Manager. Alternatively, a violation of this Code can be reported through the specific reporting channels described in Sections 6.3 and 6.4 of the Organizational Model adopted by Pharma Quality Europe S.r.l. pursuant to Decree 231/2001 (the “Organizational Model”). More specifically, any such report can be addressed to the Monitoring Body (so called Organismo di Vigilanza),
All the reports will be managed in a way to ensure to the greatest extent permitted by applicable law the confidentiality or the report and to prevent any act of discrimination and retaliation against the employee that reported a violation in good faith. Any employee who knowingly submits a report that is false or misleading will be deemed as having violated this Code and will be subject to disciplinary action.
PQE does not accept any violation report to the Code in an anonymous way, considering this behaviour unethical and contrary to the principles of the Code. Once the signed message has been read, the Internal Supervisory Board will carefully analyze it, listening, in separate and reserved locations, to both the reporter and the author of the alleged violation. PQE will act in order to ensure the reporters against any form of reprisal or act, even to the mere suspicion of being a form of discrimination or disadvantage.
In carrying out its activities, PQE has always been identified for the compliance with the current regulations, considering unethical or illegal behaviours as damaging to the relationship of trust with customers, as well as the image of the company, its reputation and credibility. Any violation to the conduct rules expressed in the Code is therefore subject to disciplinary sanctions proportioned to the gravity of the act performed, to the damage done and the previous acts, including the sanctions specifically set out in Section 8 of the Organizational Model, if applicable. As mentioned in Section 6.2 also employees who knowingly submit a report regarding the violation of this Code that is false or misleading will be subject to disciplinary action. These penalties may include, in the most severe cases, even the termination of the employment relationship.
Vision, Mission, Core Values, Customer Needs, Social Responsibility and Integrity are reflected in our Ethical Code.
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