Code of conduct

MISSION AND OBJECTIVE

PSI’s mission is to be the best clinical research organization in the world as measured by our employees, clients, investigators, and vendors. 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.

PROFESSIONALISM

We carry out our duties in a professional and reliable manner, adhering to this Code, in order to ensure the safety and well-being of those persons participating in the clinical trials PSI manages. We also aim to provide our client with high-quality services and deliverables.

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.

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.

COMBATTING CHILD LABOR, FORCED LABOR AND HUMAN TRAFFICKING

We maintain a strong commitment to upholding and respecting human rights. We do not tolerate human trafficking, forced labor and unlawful child labor in any part of our global organization or our supply chain.

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.

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 PROTECTION AND PRIVACY

We respect the rights to privacy and personal data protection of our Personnel and Partners, as well as study participants, healthcare professions, medical experts and all others involved in the clinical trials managed by PSI.

We comply with the applicable data protection laws and abide by the following data protection principles:

  • Principle of lawfulness, fairness, and transparency which involves ensuring to have the legal basis for processing personal data and informing individual about the terms of data processing and their data protection rights.
  • Principles of purpose limitation and data minimization which means using personal data for specified, explicit and legitimate purposes that are known to the individuals, and collecting the data that are necessary to achieve such purposes.
  • Principle of storage limitation by implementing rules for data retention time through our policies and business contracts.
  • Principle of data accuracy by implementing policies and processes to ensure timely correction and completeness of personal data.
  • Principle of integrity and confidentiality by implementing reasonable and appropriate security measures to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction.

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.

FAIR COMPETITION

We deal with Personnel and 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.

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.

MISCONDUCT

We do not tolerate any violation of this Code. We therefore consider it important that actual and potential illegal behavior or any other violation of this Code is reported to us so that we can investigate and sanction such practices and take the necessary corrective and preventive measures.

For this reason, we offer the opportunity to report illegal behavior or any violation of this Code through the following channel: https://whistleblowersoftware.com/secure/PSI.

We will treat all reports strictly confidential and will not retaliate against anyone who in good faith reports potential misconduct or provides information or otherwise assist in any inquiry or investigation of potential misconduct.

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.