Code of conduct

MISSION AND OBJECTIVE

PSIs mission is to be the best clinical research organization in the world as measured by our clients and our employees. In furtherance of our mission, PSI has implemented this Code of Business Conduct (the “Code”).

The Code applies to all PSI companies, subsidiaries and affiliates, all PSI employees, consultants and contractors (“Personnel”), as well as all PSI subcontractors and vendors (“Partners”). PSI expects all Personnel and Partners to understand this Code and to abide by its principles.

In order to achieve our mission, it is PSI’s responsibility to ensure that all of our Personnel and Partners perform services in accordance with the expectations and requirements of our clients, all applicable laws and regulations, as well as the business practices detailed in this Code.

PSI also expects it Personnel to perform their duties in accordance with PSI’s Core Values. We are determined to live our Core Values, which aren’t defined by what we say, but what we do, what we don’t do and what we tolerate in our presence. All PSI Personnel should refer to them and incorporate them into their work.

PROFESSIONALISM

We perform our duties in a professional and reliable manner, and in accordance with this Code, in order ensure the safety and well-being of those persons partaking in the clinical trials PSI manages, as well as the provision of high-quality services and deliverables to our clients.

COMPLIANCE WITH LAW

We uphold applicable law at all times. There are no excuses for not abiding by law and failure to do so will be taken seriously. It is imperative that we are law-abiding in all facets of our professional lives.

PATIENT SAFETY AND ICH GCP

Our priority is to conduct clinical research at the highest ethical and scientific standards. We strive to ensure and protect the safety and the rights of the patients participating in the clinical trials we manage.

We abide by The International Conference on Harmonization and Good Clinical Practice. We endorse these international, ethical and scientific quality standards for designing, conducting, recording and reporting clinical trials. We understand the importance of conducting clinical trials in accordance with these guidelines.

ANTI-BRIBERY AND ANTI-CORRUPTION

We do not tolerate bribery or corruption of any kind. We do not make or accept payments or any transfers of value that could be construed as a bribe, kickback or otherwise improper or corrupt.

In addition to this general prohibition, there are specific laws in the areas of anti-bribery, anti-corruption and anti-kickback that are directly applicable to our services and those of our clients.

If anyone detects any type of bribery or corruption on any level, large or small, it must be reported to a manager or a supervisor immediately.

INSIDER TRADING

We may be privy to proprietary new drugs, new trials and other non-public information. However, we do not use such information for financial gain or in violation of law. In particular we do not engage in any sort of insider trading.

CONFIDENTIAL INFORMATION

We understand the importance and significance of protecting confidential information and are vigilant in protecting it from improper use and/or disclosure. In furtherance thereof, we must make sure we are using and disclosing confidential information only for authorized purposes.

In case of any uncertainty about whether any document, item or piece of information constitutes proprietary or confidential information, we err on the side of caution and keep the information in confidence.

DATA PRIVACY

We respect the privacy rights and personal data of our staff, study subjects, physicians, study team members and business partners.

To protect the privacy of personal data, we abide by the following principles:

• We comply with the applicable data protection laws.
• We use personal data only for specific and legitimate purposes, and we only collect and process the minimal amount necessary to achieve such purposes.
• We inform the data subjects of our collection and processing of their personal data and allow them to exercise their rights.
• We ensure that personal data is accurate, complete and up-to-date.
• We have implemented reasonable and appropriate security measures to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction.

CONFLICTS OF INTEREST

We discourage any interaction that presents or appears to present any conflict of our interests or those of our clients. Conflicts may arise in a variety of situations, including but not limited to personal, professional and financial dealings. It is important that neither our business nor personal interactions create conflicts of interest, or improperly influence decisions.

If a conflict of interest or an appearance of one does arise, the issue should be escalated to a manager or a supervisor immediately so that it may be dealt with appropriately.

FAIR COMPETITION

We deal with staff and business partners in a fair and ethical manner. We are honest and endorse an atmosphere of fair-dealing. We do not promote any false or hyperbolic statements in order to obtain business. We strive to be forthright and do not over-promise and/or under-deliver. We endeavor to fairly represent our abilities and fulfill any promises that we make.

DIVERSITY AND INTERCULTURAL COMMUNICATION

We have a great and diverse set of skills, experiences, backgrounds and perspectives, which allows us to run cohesively in the global marketplace.

Working in international and interdisciplinary teams, we understand the importance of communicating effectively and efficiently with employees and business partners from varying cultures, backgrounds and languages. We understand and accept the differences within and among our offices and business partners. This better allows us to serve our clients throughout the world.

EQUAL OPPORTUNITY AND HARASSMENT

We are committed to being an equal opportunity employer. We do not discriminate in hiring anyone based on any legally impermissible factor, which may include race, color, religion, creed, sex, nationality, citizenship, marital status, sexual orientation, gender, gender identity, genetic information, pregnancy, disability, or military status. We encourage and understand the importance of diversity in the workplace and do not condone any discriminatory practices.

We are committed to fostering an inclusive working environment and do not tolerate harassment in any form. No one working at or with PSI should be apprehensive or scared to work due to another’s actions or retaliation for reporting discrimination or harassment.

REPORTING VIOLATIONS OF THIS CODE

We do not tolerate any violation of this Code and transgressions should be dealt with promptly. We are thus alert and responsive to situations that may have violated or could violate this Code.

Anyone who suspects a violation or has seen or heard a violation of this Code is requested to report the infraction to a manager or supervisor immediately. Otherwise, the matter cannot be resolved. The earlier a matter is reported, the more efficiently it can be addressed and corrected.

We do not retaliate against anyone for making a claim in good faith.

REVIEW

This Code will be reviewed and updated periodically to ensure it is up-to-date and inclusive of PSI values, principles and expectations. Any suggestions on how to improve upon the Code are welcome.

We believe that each individual has something valuable to contribute and we are not as strong alone as we are together.