Code of Ethics
Ethics
Values
Competencies
Ethical Behaviors
Focus on the Patient
Innovation & Continuous Learning
Focus on Results
Cooperation, Responsibility,
Authority & Accountability
Respect for Laws, Ethics & Morals
Respect for the Individual & Balance
Code of Ethics
Always act
according to our values
and put the health
of patients first.
Preamble
The Skin, Our Passion for Dermatology
Focus on the Patient
8
Clinical Research Trials
Product Safety Monitoring
Innovation & Continuous Learning
10
Discovery & Development of New Medical Solutions
Consultants, KOLs & Advisory Boards
Educational Events, Scientific Symposia, Congresses
& Scholarships
Focus on Results
14
Confidential Information
Use of Company Resources
Fair Competition
Financial Records & Accounting
Cooperation, Responsibility, Authority
& Accountability
18
Information on Our Products & Product Promotion
Interactions with Healthcare Professionals
Samples
Respect for Laws, Ethics & Morals
22
Conflicts of Interest
Bribery & Corruption
Gifts & Entertainment
Grants & Donations
Insider Trading
Respect for the Individual & Balance
26
Health, Safety, Security & Respect for the Environment
Diversity
Harassment & Bullying
Living Up to the Code
28
Index
30
table of contents
CEO’s foreword
Dear Colleagues,
The Galderma Code of Ethics is designed
to be used by all of us as a reference
that will guide our behaviours in our daily
business decisions, or when faced with
complex and challenging situations.
It is, of course, impossible for any single
Humberto C. Antunes
President & CEO
document to cover in detail all the events
or decisions that you might be confronted
with at Galderma.
This is why we advise you to always act
according to our values and put the health
of patients first, which will result in what
is best for Galderma in the long term.
Our Code of Ethics is, therefore, an
explicit declaration of adherence to
the highest ethical standards across all
parts of the Group. This allows Galderma
to be an ethical and socially responsible
company, committed to the improvement
of patients’ health through high-quality
medical solutions, while delivering value
to our shareholders.
I trust that each of you will adhere
wholeheartedly to this Code, which reflects
the values and behaviours that have made
Galderma successful over the years.
What I would like all of us to share
and realize through this document
is that our work is directed to assure and
to recover the health of the skin, and how
we do it is as important as what we do.
We appreciate fully the importance and
the noble purpose of our work, and we give
our very best to perform permanently at
the highest level.
Preamble
Galderma’s ambition is to be recognized
as the most competent and successful
innovation-based company focused exclusively
on meeting the needs of dermatology patients
and physicians.
Implicit in our ambition are commitments to
and innovation, to be accountable for highquality manufacturing, distribution
and promotion, and to ensure that healthcare
professionals and patients receive
the education and information about
appropriate use of our products.
The Galderma Code of Ethics represents
our commitment to comply with all applicable
legal requirements in the countries where
we operate. It is also intended to serve
as a framework to help us meet the high
ethical standards represented by our values.
We also have extensive policies
and procedures contained in other
supporting documents. Together,
the policies and procedures and this Code
establish our expectations.
To Whom the Code Applies
undertake and promote research
Our Code provides the ethical
guidelines and expectations
for conducting business on behalf
of Galderma. The Code is a
resource for, and applies to, all
Galderma executives, managers and
employees. It cannot address every
issue that we may encounter, but it
does provide guidance and resources
for those times when the right choice
is not clear.
External partners of Galderma, such
as subcontractors, vendors, agents
and clinical research organizations,
serve as an extension of the Company.
Our partners are expected to adhere
to the spirit of the Code when working
on Galderma’s behalf, and we may
terminate our relationships with
them if they violate our standards.
Those who oversee external partners
must never ask them to take actions
prohibited by our Code, and must
ensure that they are familiar with and
trained in the relevant requirements
of the Code and all applicable laws
and regulations. For example, external
parties promoting Galderma products
must live up to our standards and
have sufficient scientific knowledge
in order to provide precise and
appropriate information about the
products they promote.
The Skin Our Passion for Dermatology
Dermatology holds
a unique position
in the improvement
of human health
and that deserves our
undivided dedication.
Galderma is built on the concept
that dermatology holds a unique position
in the improvement of human health
and that deserves our undivided dedication.
The skin is an organ unlike others. It is our
interface with the world.
Where Galderma stands out is in the
passion that our employees, since the very
early days, have developed for dermatology
and skin health.
Skin protects, touches, warms, feels, sweats
and blushes. All of this is compromised when
the skin is sick. Our work is directed to assure
and recover the health of the skin.
Focus on the
patient
W
e have chosen to concentrate exclusively on dermatology, in
developing innovative treatments targeted at the principal diseases
of the skin and providing exhaustive services to dermatologists
and other physicians treating dermatology patients.
We consider our focus on the patient as the first of all the values
of Galderma. Above all, we will strive to continue innovating
for the advancement of dermatology in general. We are dedicated
to achieving the highest quality and strive for excellence in everything
we do, always keeping in mind the well-being and full recovery
of patients as our main goal. We therefore:
> Ensure that the best interest of patients and physicians who use our
products receive utmost consideration;
> Address the medical needs of patients, with the focus on the
favorable efficacy/safety ratio of our products; and
> Present scientific information about our products to physicians so
they are able to make informed decisions and appropriately balance
the risks and benefits of our products.
The Code provides
guidance and resources
that enable employees
to make the right
choice.
Clinical Research
Trials
requirement(s). Before a trial is initiated,
Clinical research trials are intended to
benefit for the individual trial subject and
improve patients’ health. Galderma, as a
patients at large. The rights, safety and
sponsor of clinical trials, strives to produce
well-being of the trial subjects are the most
high-quality knowledge of diseases and
important considerations and must prevail
their respective treatment, as well as to
over interests of science and the Company.
develop effective and safe therapies.
In accordance with good practices and in
Clinical trials must be conducted in
order to ensure transparency regarding
accordance with the ethical principles
clinical trials sponsored by Galderma, all
that have their origin in the World Medical
information about Phase II to IV studies are
Association’s Declaration of Helsinki, and
systematically posted on the public clinical
that are consistent with Good Clinical
data registry website: www.clinicaltrials.gov
Practices and the applicable regulatory
foreseeable risks and inconveniences
must be weighed against the anticipated
Behaving ethiCALLy
Galderma’s Competency
to live up to the Code.
> Know our key products
Model describes the be
haviors that will help
/ brands and the benefi
ts they provide to our pa
tients
> Act to make things be
tter for customers (patie
nts, physicians, healthc
professionals and intern
are
al clients)
> Continually seek to inc
rease the value of the se
rvice provided by going
beyond what customers
(patients, physicians, he
althcare professionals an
internal clients) expect
d
and by assessing their
satisfaction
> Adjust one’s approac
h as one looks for long-t
erm customer benefits
> Inspire others to delive
r high-quality service
n Our clinical research trials must
It is important that we identify, evaluate
respect patient privacy and information.
and minimize safety concerns to ensure
All patients (and/or parents or guardians)
that the overall benefits of the medicine
must be fully informed of the duties,
outweigh any risks.
benefits and risks of their participation
prior to their enrollment in the study period
and must sign an Informed Consent form.
n Any patient can withdraw from the study
for whatever reason without any prejudice.
“Patient first”
is at the center
of our medical
We strive to ensure that the interest
governance at
of the patient is served through the
galderma.
prompt detection of potential safety issues
with our products so that appropriate
communication with regulators takes place
for galderma,
n An appropriate safety follow-up by the
and, following evaluation, decisions can be
the well-being
sponsor will be performed during the study.
made and actions taken.
of the patients
n The medical care given to and medical
n We have dedicated pharmacovigilance
is the principal
decisions made on behalf of subjects must
teams across the organization that monitor,
objective of all
always be the responsibility of the qualified
review, evaluate and communicate safety
its activities.
physician.
issues to Regulatory Authorities on a regular
basis.
PRodUCt sAfety
MonitoRing
Patient safety is critically important for
the health and well-being of the individuals
n Product safety is assessed in clinical
trials before a product can be approved,
as well as after approval when a product
is being used by a large number of patients.
who use our products and is paramount
n Staff in all parts of the Company
to the success of our business. All medicine
including R&D and sales operations should
has potential risks as well as benefits,
report adverse events that come to
although not everyone who takes
their attention.
the medicine will experience side effects.
9
Innovation
& Continuous
Learning
W
e create an environment conducive to innovation. We encourage
independent creativity and an active search for new solutions.
We always support a willingness to change, learn and improve.
Mistakes are accepted as a way to experiment and learn.
We know that our edge over our competition derives from our
ability to learn and to adapt our learning to our environment. At
Galderma, we believe that training and development of employees
are essential. We seek to provide development opportunities to our
employees and we praise those who take the self-initiative to learn
on their own or seek their own source of training.
We are also dedicated to promoting continuous education
in dermatology to healthcare professionals and to patients.
Discovery &
development of new
medical solutions
conducting animal research in a humane and
ethical manner. The use of animals in testing is
thoroughly evaluated to ensure that its impact
is minimized, and consideration is given to
The discovery of new medical solutions
the use of non-animal models and alternative
makes a significant contribution to people’s
technologies whenever possible, in compliance
health through the prevention, diagnosis
with industry/government regulations.
and treatment of diseases. Research and
development is at the core of Galderma’s
business. All discovery activities are conducted
according to high ethical and scientific
standards. Our goal is to make our products
Consultants,
Key Opinion Leaders
& Advisory Boards
as safe as possible by evaluating the risks and
Galderma will seek advice and guidance
benefits at every stage, from initial research
from healthcare professionals in the
to clinical trials and then after the new product
conduct of various aspects of our business
is approved for sale.
operations, including research programs,
product development and medical,
10
All pharmaceutical products are required by
scientific and marketing issues. On such
law and regulations to be tested on animals
occasions, healthcare professionals assume
before they can be licensed for use by
the consultant’s role, providing advice,
humans. We accept our responsibility for
knowledge and expertise.
n It is appropriate for consultants who
provide services to Galderma to be offered
reasonable compensation for those
services and to be offered reimbursement
for reasonable travel, lodging and meal
Educational Events,
Scientific Symposia,
Congresses
& Scholarships
expenses incurred as part of providing
The purpose of our symposia, seminars
those services.
and other educational events is to provide
n A written confidentiality agreement, as
well as a contract specifying the nature of
balanced and unbiased education
to healthcare professionals.
‘Healthcare
professional’:
anyone
in a position
to purchase,
prescribe
or influence
the prescribing
the services, is to be provided as the basis
n All scientific or professional meetings,
of our products
of payment for those services.
congresses, conferences, symposia
(physicians,
and other similar events organized or
nurses,
sponsored by Galderma must be held in
pharmacists,
an appropriate venue that is conducive to
physician
the main purpose of the event and may
assistants, nurse
only offer hospitality when such hospitality
practitioners and
is appropriate and otherwise complies with
representatives
the provisions of any applicable code(s),
of healthcare
laws and/or regulations.
professional
n Galderma affiliates will not organize or
organizations).
n A legitimate need for the services
should be clearly identified in advance
of requesting the services and entering
into arrangements with the prospective
consultants.
n The criteria for selecting consultants
should be directly related to the identified
purpose, and the persons responsible
for selecting the consultants must have
the expertise necessary to evaluate whether
the particular healthcare professionals
meet those criteria.
n Records concerning consulting
relationships must be accurate and
retained in accordance with applicable law
and policy.
n The venue and circumstances of
any meeting with consultants must be
appropriate to the consulting services.
Activities related to the services must be the
primary focus of the meeting and any social
sponsor an event that takes place outside
their home country unless:
> most of the invitees are from outside
of the home country and, given the
countries of origin of most of the invitees,
it makes greater logistical sense to hold
the event in another country; or
> given the location of the relevant resource
or expertise that is the object or subject
matter of the event, it makes greater
logistical sense to hold the event
in another country.
or entertainment events, where permitted,
n Hospitality extended in connection with
are clearly subordinate in terms of time
professional or scientific events shall be
and emphasis.
limited to those permitted by the provisions
n It is not appropriate to pay honoraria or
travel or lodging expenses to non-faculty
of any applicable code, laws and/or
regulations.
We recognize
that biomedical
and pharmaceutical research
raises ethical
concerns,
such as the
use of new technologies, animal
research and
the conduct
of clinical trials.
We will deal
with these
concerns
responsibly.
and non-consultant attendees at companysponsored meetings, including attendees
who participate in interactive sessions.
11
n Hospitality may only be extended to
Where permitted, financial assistance for
persons who qualify as participants in their
scholarships or other educational funds
own right.
to allow medical students, residents,
n Hospitality should not include sponsoring
fellows and other healthcare professionals
or organizing entertainment (i.e. sporting
in training to attend carefully selected
or leisure) events. Galderma should avoid
educational programs or conferences may
using venues that are known for their
be offered. In any case, this is allowed so
entertainment facilities.
long as the selection of individuals who will
n When allowed, hospitality in the form of
refreshments/meals may be offered during
interaction with healthcare professionals;
however, providing tickets, vouchers or
All forms of
defraying the cost of this or any other event
hospitality offered
is not permitted.
to healthcare
professionals shall
be reasonable in
level and strictly
limited to the
main purpose
of the event.
12
receive the funds is made by the academic
or training institution. ‘Carefully selected
educational programs’ are generally defined
as the major educational, scientific or
policy-making meetings of national, regional
or specialty medical associations.
Behaving ethiCALLy
Galderma’s Competency
to live up to the Code.
Model describes the be
haviors that will help
> Show willingness to ch
ange ideas or perception
s based on the needs tha
from new information or
t arise
a new situation
> Demonstrate an indep
endent creativity in ord
er to create new approac
that have never been ex
hes
perienced by the Comp
any
> Encourage new ways
of looking at things
> Actively seek informati
on on new approaches,
methods, etc., through
Internet, readings, etc.,
network,
in order to enhance glo
bal performance
> Learn from mistakes
and address one’s own
weaknesses to take appro
preventative measures
priate
> Continually strive to de
velop methods or make
specific changes in sys
or one’s own work
tems
> Seek to learn from oth
ers and solicit ideas in
order to take certain de
cisions
> Give others support:
set time aside to work alo
ngside team members
adjust it to the actual, sp
and
ecific needs of each ind
ividual
> Promote long-term de
velopment
> Give feedback to enco
urage ongoing develop
> Share knowledge, ex
pertise, time and skills
ment
for the advancement of
others
13
Focus on
results
I
n order to contribute in a sustainable manner to progress
in dermatology, we have to work to produce the profits required
to create wealth over the long run and perpetuate the Company’s
existence. Neither results nor resources exist inside the business;
they exist outside. Results are best obtained by exploring
opportunities. Focusing on and allocating resources to opportunities
yields better results than the short-term resolution of specific issues.
Beyond mere competence, economic results are earned by leadership
and by understanding the challenges of a fast-changing global
business environment.
We will create value for our shareholders by:
> Constantly creating, improving and delivering better dermatological
solutions to patients and better alternative solutions for healthcare
professionals;
> Maintaining a strong commitment to our research and development
partners and academia;
> Maintaining fair and balanced relationships with our trade partners;
> Promoting and protecting the interests of Galderma;
> Being true to our values: being ethical in the way we seek results.
Confidential
information
such as personal data regarding our
employees, our partners or candidates
for employment with Galderma. It
The interests of Galderma might be harmed
also includes trade secrets, business,
by the disclosure of confidential information
marketing and product information,
outside or inside the organization.
market insights, engineering and
manufacturing ideas, databases, records,
14
Confidential information consists of
salary information and any
any information that is not public, or
non-published financial or business-
information that is confidential by nature,
related data.
You must not disclose confidential
As a general rule, one must avoid personal
information, or allow such disclosure to
use of company assets. Limited use of
third parties (including relatives), unless
communication tools such as e-mail,
required by law or explicitly authorized by
telephone and Internet may only be
your management and/or Legal department,
acceptable so long as it does not incur any
as applicable. This obligation applies also
unreasonable costs and does not interfere
to confidential information belonging to
with your job responsibilities. (In some
business partners and continues beyond the
markets and divisions, Galderma has released
termination of employment. Employees are
a policy on the use of IT equipment. Please
expected to return any company information
ask your local IT or HR for a copy.)
upon their termination of employment.
You should be
careful not to
discuss or work
with confidential
information in a
public area where
conversations can
be overheard or
where confidential
You must:
data can be
Employees’ personal information is
n Respect and protect Galderma assets
compromised.
considered as confidential information.
to ensure that they are not lost, damaged,
When you have access to confidential
information in the course of your work,
you must:
n Provide such information to authorized
persons only, on a ‘need-to-know’ basis.
n Make sure such information is stored
securely.
n Refrain from holding this information
longer than is necessary to meet the
legal or business reason for which it was
acquired.
misused or wasted, nor loaned to others,
transferred, sold or donated without proper
It is natural for
authorization.
us to respect our
n Avoid inappropriate use of computer
systems, corporate e-mail accounts
and the Internet.
n Recognize that all company assets
and documents belong to Galderma.
competitors and
their activity and
to treat them the
way we would like
them to treat us.
Fair
Competition
Galderma’s ambition is first and foremost
Use of Company
Resources
to respond to the needs of dermatology
patients and physicians.
Company resources are intended to
Other companies involved in dermatology
be used exclusively for allowing Galderma
have developed their own medical
to achieve its overall ambition and
products or solutions to help patients;
business goals.
given that at Galderma we are driven by
Misused or wasted company resources,
including equipment, material of all
kinds or employee time, are detrimental
to Galderma’s operational and financial
performance.
the uncompromised objective to help
patients retain or restore healthy skin, we
fully respect the freedom of choice of these
patients and doctors when it comes to a
therapeutic solution. We therefore consider
these other companies as contributors to
progress in healthcare before considering
them as mere competitors.
15
As part of its ethos, Galderma does not
Employees who are in regular contact
Collecting,
engage in any activity that would prevent
with competitors have a responsibility to
recording
patients from having access to the widest
ensure that they are familiar with applicable
and reporting
possible choice of treatment, regardless
competition laws. When in doubt, you must
data is an
of whether this treatment is provided by
contact the Legal department.
essential part
Galderma.
of everybody’s
job at Galderma.
It is therefore
As a leader in dermatology, our dealings
with competitors must be exemplary.
Financial Records
& Accounting
key to do it
We do not share any type of information,
Accuracy in financial information is
properly.
such as pricing, costs or marketing plans,
paramount for Galderma. This is an
with our competitors or partners.
essential part of running our business
Our employees must consequently:
legally, honestly and efficiently.
n Avoid any contact with competitors where
We each have a duty to make sure that
confidential information is discussed.
all our records, financial or otherwise, are
n Avoid inducing suppliers or healthcare
professionals to breach their partnership
or contracts with competitors.
accurate. In particular, it is crucial to being
able to provide transparent, regular and
reliable information to our shareholders.
n Refrain from entering in arrangements
All our employees are expected to capture
where Galderma or our business partners
and report financial information according
have or might achieve an illegal dominant
to the standards of Galderma and applicable
position.
accounting standards. In case of doubts
n Refrain from all inappropriate disparaging
about those standards or the way to interpret
remarks concerning competitors (including
them, you should refer to your Line Manager
any false statements concerning their
or Finance Manager.
products or services).
Each of us must cooperate with our internal
n Promptly disclose to their line
and external auditors whose responsibility
management if they have received or used
is to ensure the compliance of our financial
proprietary or confidential information that
reporting.
relates to competitors and legitimately
belongs only to them or to third parties.
n Collect competitive information through
legitimate means only and always identify
themselves as a Galderma employee when
If there is no other possibility, cash
transactions must be expressly authorized,
properly recorded and documented.
collecting such information.
None of us should sell, transfer or dispose
n Never allow new recruits to Galderma
of any Galderma assets without proper
to share confidential information about
authorization and documentation.
competitors for whom they might have
worked.
16
In general, we refuse all cash transactions.
Behaving ethiCALLy
Galderma’s Competency
Model describes the be
haviors that will help
to live up to the Code.
> Keep track of (monito
r) and measure outcome
s against a standard
of performance
> Pay attention to the pro
per level of quality and
> Take actions beyond
deadlines
normal expectations
> Try to accomplish tas
ks better, faster, more effi
> Display persistence in
> Recognize and react
ciently
order to improve perform
ance
> Adjust personal worki
to present opportunities
ng habits in order to inc
rease efficiency
> Stay informed about
‘best practices’ in one’s
area of expertise, in ord
to improve one’s persona
er
l efficiency
1
Cooperation,
Responsibility,
Authority
& Accountability
O
ur success depends on our ability to combine our varied talents and our
diverse perspectives, and to build on one another’s ideas and passions.
At Galderma, we believe that the way we go about carrying out our
business, individually and as teams, is in itself a source of motivation
and a condition for lasting performance.
We seek every opportunity to build relationships, trust and expertise.
We know that effective cooperation, both:
> internally within Galderma, across divisions, countries and
departments; and
> externally with our business partners and suppliers
will create greater value for the Company.
We are empowered to act, we accept responsibility and we
hold ourselves and others accountable. We want people to take
responsibility for their actions and empower them with authority.
Along with that comes a personal accountability for our actions.
Performing one’s role responsibly means knowing what can be done
and how to do it, with the interests of Galderma in mind and without
compromising the integrity of our values and policies.
Information
on our Products
& Product Promotion
18
should be accurate, fair, balanced and
comprehensive, to enable a full risk-benefit
assessment of our products.
Patients and healthcare professionals
n Be sure promotional discussions
rely on us for accurate and complete
and information used or distributed
information about our products. Therefore, it
is accurate, balanced, fair, complete
is vitally important that product information
and not misleading. The information should
includes the most recent scientific and
be based on an up-to-date evaluation
technological advances. Product information
and all relevant evidence.
n We will never promote Galderma products
the prescribing of our products.
for off-label use. When physicians decide to
Physicians, nurses, pharmacists, physician
use a product outside its indications, they
assistants, nurse practitioners and
do so under their own medical responsibility.
representatives of healthcare professional
All product claims must be consistent with
organizations.
the approved product labeling.
n Galderma shall ensure that its medical
n Promotional activities must be transparent
representatives and other personnel
and auditable. Artwork that is part of
promoting our products are adequately
the promotional material must not be
trained and have sufficient scientific
misleading. When promotional material
knowledge in order to provide precise and
refers to published studies, clear references
appropriate information about the products
must be given.
they promote.
n No product should be promoted prior to
n Medical representatives and other
& Procedures,
the grant of the marketing authorization.
personnel promoting our products must
Medical section).
n Respond promptly to requests from
healthcare professionals for substantiation
of claims that have been made or for
additional supporting evidence.
comply with relevant requirements of the
Please refer
to our Company
policies and
procedures
regarding Product
Promotion on the
Galderma Portal
(Policies
applicable code and all applicable laws and
regulations.
n During each visit, medical representatives
and other personnel promoting our products
Interactions
with Healthcare
Professionals
must have available, if requested, an
approved product label for each product
they present.
n Medical representatives and other
Our relationships with healthcare
personnel promoting our products must not
professionals are intended to benefit
use any unlawful inducement or subterfuge
patients and to enhance the practice
to gain an interview with healthcare
of medicine. Ethical and professional
professionals.
relationships with healthcare professionals
are critical to our ambition of helping
dermatology patients by developing
and marketing new medicine.
n Medical representatives and other
personnel promoting our products must
approach their duties responsibly and
ethically.
As used at Galderma, ‘healthcare
n Every Galderma affiliate must establish
professional’ means anyone in a position
a Medical/Regulatory Affairs department in
to purchase, prescribe or influence
charge of information about its products.
19
Samples
are not given
Samples
to healthcare
In accordance with national or international
professionals for
laws and regulations regarding the
their personal use
marketing of drugs, a limited number of free
or that of their
samples of a particular product may
families.
be supplied to healthcare professionals who
are qualified to prescribe or recommend
that product in order to familiarize them with
the product.
n Affiliates must have adequate systems
of control and accountability for samples
20
that they distribute and for all medication
handled by its representatives.
n Each sample must be marked ‘free
medical sample – not for resale’ or words to
that effect and, as appropriate, must
be accompanied by a copy of the approved
product labeling.
n Employees may not take samples for
their own use, even if they are healthcare
professionals.
Behaving ethiCALLy
haviors
Model describes the be
y
nc
ete
mp
Co
a’s
rm
lde
Ga
Code.
will help to live up to the
> Know and perform the
responsibilities
that
e’s
tasks associated with on
countable for expected
> Focus on and feel ac
results
d
ognize the knowledge an
> Sincerely value and rec
contributions of others
s and to the Company
lleague
> Be loyal to peers / co
as a whole
ard a common
s’ concerns and act tow
> Share other colleague
goal
organization
n across all parts of the
tio
era
op
co
ge
ura
co
En
>
ers
and with external partn
each team
what is expected from
> Clearly communicate
ions and
reasons behind our decis
member and explain the
choices
ation
eive all necessary inform
mbers rec
> Ensure that team me
to carry out their work
ir input
the
accountable and ask for
> Hold team members
s
before making decision
nt position: act as
> When in a manageme
empower people
a leader and
21
Respect for Laws,
W
Ethics
& Morals
e strive to respect all laws and regulations and comply with the best
standards of behaviour in each country in which we operate. We will
lead by behaving ethically and by keeping high moral standards.
Honesty is an absolute must.
It is important that each of us is aware of relevant laws and regulations
that apply to our work and that we never engage in conduct that
violates applicable laws and regulations.
Wherever Galderma operates, it does so in accordance with its own
values, one of which is ‘Respect for the Law’. It recognizes and
respects the culture, the political system and the laws of the countries
where it carries out business.
Galderma contributes to the health of patients and to the management
of public health in countries where it markets its products.
Conflicts
of Interest
You must refrain from holding any position,
involvement or financial stake in any
organization that is a competitor, customer,
Conflicts of interest might occur when
supplier or any other business partner of
you find yourself in a position that might
Galderma, if your position at Galderma
influence or appear to influence your
allows you to influence the business
judgment and actions (for example,
relationship.
where a family member is employed by
a supplier). In such situations, it can be
We encourage selected managers to
difficult for the employee to act fully in
represent Galderma within dermatology
the best interest of Galderma.
or pharmaceutical industry institutions;
however, these activities must be carried
You must avoid conflicts of interest
out with the interest of the Company
whenever possible. If you face a situation
in mind and in strict compliance with our
that may involve or lead to a conflict of
guidelines.
interest or if a conflict of interest situation
has occurred, you must disclose it to
Unless requested by Galderma to take up
your Line Manager and/or to HR or Legal
a particular position or activity, employees
to resolve the situation in a fair and
can only pursue outside industry-related
transparent manner.
activities and positions at their own risk
and cost and within their spare time, and
22
after informing their manager.
When immediate family members and
retain a business or other advantage from
partners of an employee also work for
a third party, whether public or private.
Galderma as consultants or employees,
To accept any such advantage in return for
If you have doubts
appropriate Galderma management must
any preferential treatment of a third party
or questions
ensure that the employee and his or her
is also considered corruption.
regarding
relative or partner are not exposed to
situations that are likely to lead to any
conflict of interest or non-compliance
regarding any internal procedure.
As a pharmaceutical company, Galderma
deals routinely with government bodies. It is
clearly in the long-term interest of Galderma
to establish this relationship solely on
The employee and his/her relative or
the basis of good business practices and,
partner cannot have a direct reporting
therefore, avoid making or receiving any
relationship or hold positions that interact
illegal payments to or from these bodies
in the same work processes, in a way that
or their representatives, whether official or
might expose the incumbents to conflict of
unofficial.
interest situations.
the legal and
regulatory
obligations that
apply in a given
situation, you
should seek advice
with the Legal or
Regulatory Affairs
department.
Our employees must, therefore, never make
Employees must never engage in activities
any illegal or improper payments to third
As an employee
that may compete with Galderma, nor must
parties – which means carefully selecting
of Galderma,
they take personal advantage of business
and monitoring contractors, agents and
you receive
opportunities that they discover during
business partners.
compensation for
your work. Beyond
the course of their employment, unless the
Company expressly waives its interest
in pursuing such opportunity in writing.
Bribery
& Corruption
Gifts
& Entertainment
this normal
compensation,
you should not
Exchanging gifts and entertainment can
draw any financial
help build understanding and improve
advantage from
working relationships, but they can also
your work at
Corruption, whether direct or through
cause a conflict of interest between
Galderma, whether
others, whether active or passive, is
personal interests and professional duties.
for yourself,
unacceptable to Galderma.
In some countries or cultures, exchanging
Bribery is a form of corruption and is illegal
gifts between business partners is
in most countries.
customary. This is why employees of
Bribery or corruption occurs when a person
directly or through intermediaries offers or
promises any personal or improper financial
or other advantage in order to obtain or
your relatives or
acquaintances.
Galderma are expected to follow strictly the
policy applicable in their market. If no such
policy is available, they should seek advice
with their manager or with the Legal or
Regulatory Affairs department.
23
When giving
or accepting gifts,
entertainment
or meals, the
Golden Rule
is reasonableness
and consideration
of how it would
be perceived
by others.
Employees must never give or accept cash
n No gift, pecuniary advantage or benefit
gifts. They shall neither accept or offer gifts,
in kind may be supplied, offered or
meals, or entertainment if such behavior
promised to a healthcare professional as
could be seen as improperly influencing
an inducement to prescribe, supply, sell,
the respective business relationship.
recommend or administer a product.
Special care must be extended in
n Gifts for the personal benefit of
relationships with healthcare professionals.
healthcare professionals (such as tickets to
No monetary or other considerations are
entertainment events) should not be offered
to be given to healthcare professionals
or provided.
for the purpose of gaining improper access
n Many healthcare professionals must
or influence.
follow rules and guidelines set by their
n Where products are being promoted
employer or government. Galderma
to healthcare professionals, no gifts,
employees need to abide by these
pecuniary advantages or benefits in kind
standards.
may be supplied, offered or promised to
such persons unless they are inexpensive
and relevant to the practice of medicine
or pharmacy. Except when displaying all
the product information, items may bear
no more than the name and logo of the
Company and/or the name of the product,
and/or its international non-proprietary
name, where this exists, and/or the
trademark.
24
Grants
& Donations
Donations, including donations in kind,
may be provided to organizations involved
in promoting charitable, community,
educational, humanitarian, health, and
philanthropic, cultural or artistic activities.
Behaving ethiCALLy
Galderma’s Competency
to live up to the Code.
> Express one’s opinion
Model describes the be
haviors that will help
honestly
> Act in accordance wit
h one’s beliefs, even wh
en it is difficult
> ‘Walk the talk’, encoura
ge openness and hone
sty, and honour commitm
in relationships with oth
ents
ers
> Be able to openly admi
t mistakes
> Act in a way to become
an example of honesty
and openness for one’s
team
> Speak up when you dis
agree with management,
clients or others
‘in power’, but disagree
politely, stating one’s vie
w clearly and confidentl
even in a conflict
y,
Galderma entities must ensure that such
This obviously applies to the trading of
While we do not
donations are not made for product
Nestlé or L’Oréal shares, as well as to
wish to restrict
promotion purposes in their respective
shares of companies that we, or our
the freedom
territories. Donations should never be
shareholders, are potentially considering
of our employees
provided to healthcare professionals
for a partnership or an acquisition.
to make
as a way to promote specific Galderma
products.
Each of us must be aware that insider
trading may not only entail disciplinary
Galderma has adopted a policy that bans
sanctions but also result in criminal
contributions by any Galderma entity to
charges.
political parties or candidates.
appropriate
personal
investments,
each of us must
always bear in
We must therefore refrain from buying or
mind that using
selling shares of Nestlé or L’Oréal or of
confidential
any other company when we have inside
information to
information at that time. Avoid disclosing
make investments
Unauthorized disclosure of confidential
such inside information to anyone outside
is inappropriate
information may be detrimental to
Galderma, including family members.
and might fall
Galderma and its shareholders.
Avoid disclosing such inside information
within the scope
insideR
tRAding
to anyone within Galderma, except on
of insider trading
Insider trading might occur when you
a ‘need-to-know’ basis. Protect inside
laws.
trade shares of a company on the basis of
information from accidental disclosure.
potentially share-price-relevant information
When in doubt regarding the interpretation
not made available to the public.
or applicability of Galderma insider trading
rules, employees shall consult with the
Legal department.
2
Respect for the
Individual
&
W
Balance
e uphold the self-esteem and dignity of the individual and each other’s
culture. We foster an environment of reciprocal respect conducive for
the expression of views and ideas, irrespective of hierarchy. We value
positive qualities, such as efficiency, enthusiasm at work, tranquility
under pressure, courtesy and empathy. We do not encourage
malingering, idleness, panic and constant argumentativeness. We
respect those who speak their minds, but not those who do so out of
arrogance or self-righteousness.
We believe the individual is one and indivisible, but also multiple
in his/her interests. Therefore, we seek a balance between work
and personal life. We believe it is important to have time to pursue
personal interests, to work in a respectful and pleasant environment
and to have a full and content family life.
Health, Safety,
Security & Respect
for the Environment
n Report to management any behaviour,
installations or items likely to compromise
the safety of our working environment, as
well as all accidents, however minor; and
As a contributor to the improvement of
public health, Galderma considers that:
n The safety of its employees, visitors and
n Discuss any health or safety issue we
encounter with our Line Manager, Safety
Officer or HR Manager.
on-site contractors is not negotiable; and
n Protecting the environment contributes
to human well-being.
Each of us must:
direct impact on the environment. Whether
we are manufacturing or distributing
our products, managing our facilities or
n Ensure we are not putting ourselves or
marketing and promoting our products, we
others at risk by our actions;
must have a constant objective to ensure
n Comply with the applicable rules on
that these activities have a minimal impact
health and safety at work, and take every
on the environment and find the best ways
reasonable precaution to maintain a safe
to monitor and correct any such impact.
and healthy working environment;
n Ensure that we know what to do if
an emergency occurs at our workplace;
26
Many of our activities as a company have a
Each of us can contribute to this effort by:
n Abiding by our internal and external
environmental codes and regulations;
Behaving ethiCALLy
Galderma’s Competency
to live up to the Code.
Model describes the be
haviors that will help
> Explicitly recognize tea
m members’ contributio
ns and performance
> Strive to promote an
open and friendly clima
te and resolve conflicts
in order
to enhance effectivenes
s of all members
> Ask for team members
’ input before making de
> Set a good example by
cisions
demonstrating positive
behaviours
n Favoring the use of renewable raw
> Political and philosophical opinions
materials and the development of
> Religious beliefs
environmentally friendly packaging;
n Being aware of and sensitive to
the impact that our work has on the
> Union activity
> Racial, social, cultural or national origins
environment, so that we can reduce that
This applies to our daily work and to our
impact wherever possible. For example,
relationships with colleagues, doctors,
we can minimize travel, save water and
business partners or candidates. It also
energy and avoid generating waste. Where
applies to recruitment, decisions relating to
waste is unavoidable, we must ensure
training, promotion, continued employment
materials are recycled or disposed of
and working conditions in general.
in a responsible fashion; and
n Reporting immediately all spills or unusual
emissions to the air or water to management
or the Health and Safety Officer.
diVeRsity
Galderma has long operated as an
international business and has employed
people of different nationalities, cultures
and education. As a global Company,
we consider diversity as a condition for
stronger corporate performance.
All those
who work with
and for galderma
are entitled
to a healthy, safe
and secure working
environment.
diversity is
at the heart of one
We are proud of Galderma’s dedication to
of our core values:
diversity and make sure that people we do
‘Respect for the
business with are aware of and respect our
individual’. it is
opinion regarding diversity.
a key galderma
attribute that
hARAssMent
& BULLying
appeals to our
employees or
candidates whom
We strongly condemn any form of
galderma seeks
psychological or sexual harassment or
to attract.
bullying, regardless of the employee’s
position or the country in which he or she
operates. We expect our employees to treat
At galderma,
We, therefore, do not discriminate
others at work the way they would like to
‘Respect for the
on the basis of:
be treated. We also expect all employees
individual‘ means
to respect the dignity and the physical
that we consider
and psychological integrity of our patients,
human dignity
colleagues and any of our business partners.
and integrity as
> Gender
> Disability
> Family situation
fundamental to
> Sexual orientation
the way we do
> Age
business.
2
Code
Living Up to the
To ‘do the right thing’ and to ensure
issues may arise that this Code and our
the highest standards of integrity is the
policies do not answer. Or you may observe
responsibility of each Galderma employee.
demands, practices or actions that you
This responsibility cannot be delegated.
believe to be violations of this Code or the
The head of the division, country or
law. In these situations, you are expected
department is ultimately responsible for
to seek guidance or raise concerns with
ensuring adherence to the Code.
your Line Manager or with the HR or Legal
Because violations of this Code or the law
departments.
can cause so much harm to colleagues,
If you have raised the issue and you are not
shareholders, healthcare professionals
satisfied with the answer you were given,
and patients, failure to comply with this
or if you feel that it is more appropriate to
Code may result in disciplinary action,
report the situation elsewhere, there may
including the possibility of dismissal and,
be additional resources available in your
if warranted, legal proceedings or criminal
division, country or department, such as
sanctions.
staff representatives, grievance procedures
Our Principles, this Code, and the policies
or a helpline. You may also contact a
that underlie it are the foundational
member of the Galderma Ethics Council. To
guidance for doing the right thing and
do so, you should write to:
acting in compliance. However, sometimes
[email protected]
As a
MAnAgeR
ical conduct.
egrity and promote eth
of int
> You must set an example
in decision-making
e appropriately the Code
us
to
le
ab
be
st
mu
u
> Yo
ues.
complex and difficult iss
and dealing with more
m for advice
elf available to your tea
> You must make yours
and help.
ur employees
icate the Code to all yo
> You should commun
ng.
ve received proper traini
and ensure that they ha
28
investigation. ‘Good faith’ means that you
of Galderma are:
have provided information that you believe
• The Chief Medical Officer,
to be honest and accurate at the time, even
• The Vice President Human Resources,
if you are later proven to be mistaken.
• The General Counsel – Galderma
We will ensure a fair process in case of
International,
an investigation and, in particular, respect
• The General Counsel – Galderma
the principles of due process and the
Laboratories L.P.
presumption of innocence. All information
index
The members of the Ethics Council
given in the course of an investigation will
Its role is to assist management and
be communicated on a ‘need-to-know’
employees in dealing with sensitive or
basis. Full cooperation is expected during
complex ethical matters. It will suggest the
such investigations.
appropriate course of action or call upon
Any employee raising a concern in good
expert advice, within or outside
faith will be protected against retaliation.
the Company, to resolve the matter.
We will provide feedback to the individual
We do not encourage anonymous reports.
who has raised the concern, to the extent
Given the reporting process in place,
that it is appropriate and can be given
we believe that it is unnecessary for an
without infringing legal requirements or
employee reporting a concern in good faith
other duties of confidentiality.
to conceal his or her identity. However,
Galderma will investigate and review any
such anonymous reports
as appropriate.
It is our policy that any concerns raised in
good faith about misconduct on the part
of the Company or any of its employees
or business partners are thoroughly
investigated, and that appropriate actions
are taken to deal with the outcome of that
29
Accountability, 18, 20, 21
Education
Authority, 18, 21
Education in dermatology, 6, 10
Accounting, 16
Educational events, 11
Advisory Boards, 10
Animal testing, 10, 11
Auditors, 16
Benefits in kind, 24
Educational funds, 12
Educational programs, 12
Employment/Employee, 6, 10, 14, 15,
16, 20, 22, 23, 25, 26, 27, 28, 29
Personal interest, 23, 26
Personal use of communication
tools, 15
Personal use of Company
assets, 15, 16
Pharmacovigilance, 9
Product
Entertainment, 11, 12, 23, 24
Claims, 19
Environment (respect of), 26, 27
Information, 6, 8, 14, 18, 19, 24
Ethics council, 28, 29
Off-label use, 19
Cash gifts, 23, 24
External partners, 6, 14, 15, 16, 18,
21, 22, 23, 25, 27, 29
Samples, 20
Cash transactions, 16
Fair competition, 15
Claims (product), 19
Financial records, 16
Clinical trials (studies), 8, 9, 10, 11
Free samples, 20
Best practices, 17
Bribery, 23
Bullying, 27
Company resources, 15
Competencies, 9, 13, 17, 21, 25, 27
Competitors, 15, 16, 22
Confidentiality, 29
Confidentiality agreement, 11
Good faith, 29
Gifts, 23, 24
Good practices, 8
Grants, 24, 25
Grievance procedure, 28
Promotion, 6, 18, 19, 24, 25
Promotional activities, 19
Protection of the Company assets, 15
Reporting data, 16
Reasearch, 10
Respect for ethics, 22, 23, 24, 25
Respect for laws, 22, 25
Respect for morals, 22, 25
Respect for the environment, 26, 27
Harassment, 27
Responsibility, 9, 10, 16, 18, 19, 21,
28
Congresses, 11
Healthcare professionals, 6, 10, 11,
12, 14, 16, 18, 19, 20, 24, 25, 28
Safety
Consultants, 10, 11, 23
Human dignity & integrity, 26, 27
Confidential information, 14, 15, 16, 25
Conflicts of interest, 22, 23
Employee safety, 26, 27
Patient safety, 8, 9
Confidentiality agreement, 11
Innovation, 6, 10, 13
Honoraries & travels, 11
Insider trading, 25
Samples (product), 20
Key opinion leaders, 10, 11
Scholarships, 11, 12
Loyalty, 21
Seminars, 11
Market insights, 14
Shareholders, 14, 16, 25, 28
Medical representatives, 19, 20
Subcontractors, 6, 23, 26
Misconduct, 29
Suppliers, 16, 18, 22
New medical solutions, 10
Symposia, 11
Off-label use (product), 19
Technologies (new), 10, 11
Patient, 6, 8, 9, 10, 15, 16, 18, 19, 27
Trade secrets, 14
Continuous learning, 10, 13
Contributions to political parties, 25
Cooperation, 18, 21, 29
Corruption, 23
Creation of value, 9, 14, 18
Disciplinary action, 25, 28
Disclosure of information, 14, 15, 25
Discovery, 10
Discrimination, 27
Diversity, 27
Dominant position, 16
Donations, 24, 25
Product safety, 8, 9
Patient privacy, 9
Training, 10, 12, 28
Patient safety, 9
Transparency, 8
Performance, 13, 15, 17, 18, 27
Values, 6, 8, 14, 18, 22, 27
Personal data, 14
Working environment, 26, 27
30
To ‘do the right thing’
and to ensure the highest standards
of integrity is the responsibility
of each Galderma
employee.
02/2010
Photos: Galderma, iStockphoto, Getty images,