BRANDING SCIENCE GROUP (BRANDING SCIENCE): CODE OF CONDUCT
Introduction
Our company’s mission is to enable pharma to make better decisions for better patient futures. We deliver on this mission through our company values, namely:
- Self-Belief: believe in yourself and the team; dare to take opportunities
- Passion: serve with drive and purpose
- Courage: dare to not take the conventional path; have the courage of your convictions and do what is right
- Growth: support an environment where professional and personal goals are shared, encouraged and achieved. Learn and share your knowledge, growing with others.
- Smarts: think intelligently; be mindful and solution oriented
- Respect differences: cultivate and encourage diversity of opinions
This Code of Conduct is built on these values, and gives clear expectation and guidance on how we conduct business and our commitment to ethics and integrity. All of us share the responsibility to live by this Code.
‘Business ethics’ is the common term for the steps we take to protect our business and our business partners from engagement in any form of corruption and bribery. It is a way to create long-term business value, in our efforts to make Branding Science a sustainable business. We follow simple and clear rules, engage responsibly with stakeholders, transparently account for the financial transactions we make and work against corruption in all its forms. This is a way to demonstrate financial and social responsibility.
Not every situation you face may be addressed in this Code of Conduct; if you are unsure how Branding Science’s standards or values apply in a given situation, please ask questions and seek further guidance from any of the following:
- Chris Waters: Group CFO
- Delveen Mallak: Chief P&C Officer
- Moniola Olusanjo: Global Compliance Officer
You must read this Code of Conduct, keep it in mind and use it to guide your decisions and actions.
Peter Cunningham (Founder and Group CEO)
To Whom this Code of Conduct Applies
Branding Science employees
- All employees should read this Code of Conduct and apply its principles to your daily work
- If in any doubt on any issues relating to ethics or compliance, raise it at the earliest opportunity to your P&C or Compliance team
- Share and communicate this Code of Conduct with your colleagues, third parties, and external stakeholders
Branding Science Managers / Senior Staff
- Ensure that all of your employees who report to you read and understand this Code of Conduct, and guide and educate them on how to do their daily work in an ethical manner
- Promote a speak-up / feedback culture where all ethics and compliance issues are reported and handled
- Lead by example in ensuring your decisions are in line with the Code of Conduct and are framed in an ethical mindset
- Show your team that results matter by acting in the right way
Suppliers
- Branding Science suppliers should read and adhere to this Code of Conduct
- A link to this Code of Conduct will be provided in all Supplier agreements
1. Branding Science Group’s Commitment to Business Ethics
Branding Science is committed to the highest ethical standards of business conduct. We operate around the globe and respect and comply with the law wherever we do business. For example, we focus on complying with all local and international anti-corruption laws, regulations, standards, policies and procedures that may apply to our business such as the U.S. Foreign Corrupt Practices Act, the U.K. Brib ery Act and the UN Guiding Principles on Business and Human Rights.
We also ensure that we comply with applicable pharmaceutical laws and regulations governing our work with our clients.
Our Code of Conduct serves as a guide for ethical decision-making. Business ethics is about acting with integrity, and with respect for the integrity of others and in compliance with international standards for responsible business conduct. One key focus for business ethics is to prevent corruption, fraud and theft in all its forms, ranging from extortion and bribery to other ways of exercising undue influence. We take this very seriously through continued employee training, and employee and supplier contract wording. We hold ourselves accountable for our actions, and are transparent about our decisions and practices.
This Code of Conduct details what integrity means to the company and sets the global standard for business ethics conduct. In some countries, local laws, regulations, industry codes or local Branding Science company policy may set specific requirements that are more stringent than this Code of Conduct. Where this is so, we follow the more stringent rules.
This Code applies to anyone who conducts business for or on behalf of Branding Science including:
- All employees
- Executive Management and Board of Directors
- External business partners who act on Branding Science’s behalf or in our interest as Third Party Representatives
Not every situation you face may be addressed in this Code of Conduct; if you are unsure how Branding Science standards or values apply in a given situation, please ask questions and seek further guidance from key contacts as detailed on page 1.
Each and every one of us are responsible for ensuring that we follow the highest ethical standards of business conduct, and we will be held accountable for upholding our commitments to our Branding Science values, this Code of Conduct and the related policies and procedures.
2. We speak up
Branding Science fully encourages an open and honest culture of trust and integrity. Part of building such a culture of trust is speaking up about any ethical or compliance concern so we can address possible issues as soon as possible. By speaking up, employees are doing the right thing and contributing to an ethical culture at our Group.
If you are unsure of how our standards or values apply to a given situation, or if you suspect a potential compliance deviation, you are responsible for raising it through the appropriate channels.
2.1 How to report a concern
Anyone who becomes aware of an actual or potential violation of this Code of Conduct can and should speak up. If you feel comfortable, talk to your manager about it. Such conversation may easily remedy many issues. If you are not comfortable with this, or appropriate action is not being taken to address an issue, please contact:
- Your local Compliance function
- Your P&C team or Group CFO
- Through our Whistleblowing Policy link
Both employees and external partners can anonymously report concerns to our Whistleblower policy, which can be read on our Intranet or shared on request, within which is the link to be able to report any issues anonymously.
2.2 Non-retaliation
We have no tolerance for retaliation at Branding Science. You will not suffer any adverse consequences for:
- Refusing to do something that violates this Code of Conduct, our requirements, or the law, even if your refusal results in the loss of business to Branding Science
- Raising a concern in good faith about potential misconduct
- Cooperating with an investigation
Anyone who retaliates against an employee for engaging in any of these activities will be subject to disciplinary action, up to and including termination.
3 General Business Ethics
Branding Science is committed to fostering an open and honest culture of trust and integrity. We interact responsibly, ethically and transparently with all our stakeholders.
We are truthful in our interactions with patients, clients, and stakeholders and we do not offer, promise, provide, or accept anything of value in order to inappropriately influence a decision or gain an unfair advantage. We do not allow others to give bribes on our behalf. This applies to all interactions with our stakeholders.
Compliance with the laws and international standards for responsible business conduct inspires trust in our culture of integrity. We comply with all laws, regulations, policies, standards and procedures that apply to our business.
Remember that perception matters. Your behaviour can be considered a bribe or an improper advantage regardless of your intention.
3.1 Bribery and improper advantages
At Branding Science, we compete fairly and are responsible, ethical and transparent in our business. We do not bribe or provide improper advantages. Bribes and improper advantages can be monetary such as cash payments or illegal rebates, but they may also include non-monetary items such as improper gifts, products, hospitality and meals, travel and accommodation, or other items or services that ultimately mean the transfer of value in return for special consideration.
Keep in mind that when you give or receive gifts, hospitality or entertainment in interactions with third parties and external stakeholders, this may lead to a conflict of interest and be seen as a bribe or improper advantage.
However, legitimate business expenses for items such as meals, travel and accommodation may be explicitly allowed by local law, regulation and company policy depending on the recipient and the circumstances.
It does not matter whether you use your own private money or Branding Science’s funds to pay a bribe or improper advantage or do so via a third party. All are against this Code of Conduct.
Branding Science prohibits facilitation payments worldwide. A facilitation payment broadly means any unofficial transfer of value to a Public Official for taking routine governmental actions.
3.2 Fraud
We are committed to preventing and detecting fraud – we do not engage in any kind of fraud against Branding Science, any of our business partners or government entities. Generally, fraud means deliberately deceiving a person or company to unjustly obtain an unauthorised benefit, such as money, property or services:
- Theft of funds, inventory or any other asset from Branding Science, including false expense reports
- Manipulation of accounting information or financial statements
- Misuse or forgery of any document (for example records, data, accounts, expense claims or contracts)
3.3 Books and Records
We ensure the integrity of our business transactions by keeping documents and records organised, accurate, and complete.
Records such as invoices, employee expenses and any transfer of value to a company, organisation or individual outside Branding Science Group should reflect the nature of the business purpose, business transaction, and be truthful, complete and unaltered.
3.4 Conflicts of Interest
Our decisions are based on what is best for Branding Science and our clients, rather than any personal advantage.
We make decisions based solely on objective criteria and professional judgement, and are never improperly influenced by our personal, social, financial or political interests. Allowing a competing interest to interfere with good decision making can put our reputation for honesty and fairness at risk.
3.5 Data Privacy
We respect the personal data that we collect from our employees, patients, Healthcare Professionals (‘HCPs’), and other stakeholders. We are committed to complying with all applicable laws related to data privacy.
When you use personal data as part of your work in Branding Science you must:
- Use the least amount of personal data needed
- Where required by local law and regulation inform people on how we use their personal data
- Only share personal data with those who need to know
- Store personal data securely
- Delete personal data when no longer needed
Further details on our data privacy policy can be found here: https://branding-science.com/privacy-policy. If in any doubt on any data privacy issue, please reach out to [email protected].
3.6 Human Rights
We respect internationally recognised human rights. Our mission is to avoid infringing on the human rights of our employees, patients, workers in our supply chains, communities and other stakeholders.
We strive to prevent and mitigate adverse human rights impacts with which we are involved, either in our own business operations or through business relationships. We promote a positive and inclusive work environment that respects the individual and is free from any form of discrimination or harassment.
Branding Science is committed to fostering a safe and respectful work environment. Any form of harassment towards staff, whether by employees, representatives, suppliers, or agents of those parties, will not be tolerated. If concerns of harassment are raised by any employee, we reserve the right to investigate promptly. Based on the findings, we may terminate the agreement immediately, without any fees or repercussions, to protect our staff and uphold our standards of conduct. By accepting this Code of Conduct both parties acknowledge and agree to adhere to this policy.
3.7 External support
We are socially responsible. We partner with and give contributions or our expertise to organisations in support of a wide range of charities.
We never offer or give contributions to unduly influence the recipients or to undermine their independence. Support may not be connected with or conditioned upon the past, present or future prescribing, purchasing, or recommendation of any Branding Science proposal.
3.8 Social Media and Digital Solutions
We use social media and digital solutions in a compliant way, both for business communication and private purposes.
We never use social media to improperly promote Branding Science products. For business-related communication, we only use digital solutions that are controlled or approved by Branding Science for business-related communication and if we have permission to do so from all relevant stakeholders.
We support the responsible use of digital solutions and new technologies that contribute to better quality of work for our clients, and thereby ultimately patients.
3.9 Sustainability and the Environment
We continue to strive to improve our Ecovadis score annually by improving measures in Environment, Labour & Human Rights, Ethics, and Sustainable Procurement, in order to improve our Group’s performance across the board in all of these areas.
We ask that our partners and suppliers strive to improve in these areas also, and we will look to prioritise working with those suppliers that are doing so.
4 Business ethics in our interactions
4.1 Public Officials
We interact with Public Officials ethically, responsibly, and transparently. We never give or offer anything of value to a Public Official to unduly seek influence.
The term Public Official broadly covers politicians, officers, and others employed in any governmental body, its departments, agencies or instrumentalities in companies owned or partially owned by a government, or in international governmental organisations (such as the UN). Most medical and scientific personnel are seen as Public Officials when they work in government-owned hospitals, clinics, universities or similar facilities. In many countries, Public Officials also include HCPs.
It is important that you recognise that our interactions with Public Officials are subject to strict international laws and local rules in the countries where we operate.
4.2 Healthcare Professionals and Healthcare Organisations
We believe that interactions with HCPs and Healthcare Organisations (‘HCOs’) have a profound and positive impact on the quality of patient treatment and future innovations.
We are committed to the highest ethical standards and compliance with applicable laws and regulations in every aspect of our relationship with HCPs and HCOs.
The terms HCP/HCO broadly cover members of the medical, dental, pharmacy or nursing professions or any other person or entity who, in the course of their professional activities, may prescribe, purchase, supply, recommend, or administer a medicinal product.
We interact with HCPs and HCOs in many ways, including our research / fieldwork and activities. All these interactions must be based on a valid scientific and business purpose and in compliance with all applicable laws and industry codes. We never give or offer anything of value to HCPs or HCOs to unduly influence their decisions and we comply with all laws and regulations on transparency reporting.
4.3 Patients and Patient Organisations
At Branding Science we put the patient at the heart of every decision. We treat patient information with respect and protect their confidentiality.
We consider the exchange of information with and value insights from patients and patient organisations to be vital for our work with our clients. We are guided by the principle that a patient-centered business approach delivers better outcomes for patients.
We support empowerment of the patient voice and collaborate with patient organisations and other relevant stakeholders to improve prevention, treatment and access to quality care for people living with chronic diseases.
We comply with applicable local and international laws governing our interactions with patients and patient organisations. We ensure transparency, inclusiveness and high ethical standards in our interactions with patients and patient organisations. In addition, we respect the codes developed by individual patient organisations and their independence, as well as guidance from BHBIA and EPhMRA.
4.4 Third Party Representatives
We believe that partnering with others is paramount to achieving our goals to develop innovative and competitive solutions for patients’ unmet needs.
We hold ourselves to high ethical standards, and we also expect our representatives who work on our behalf or in our interest to meet the high standards of performance and integrity we set for ourselves. We encourage them to expect the same of their business partners.
There is a special focus on external companies or individuals that represent Branding Science in critical business matters, i.e. that provide certain services and, as part of the performance of such services, act on behalf of or in the interest of Branding Science towards Public Officials, HCP/HCOs, patients and patient organisations. Some of these services may be related to marketing activities on our behalf.
We refer to these companies or individuals as Third-Party Representatives (‘TPRs’). Before entering into an agreement with a TPR, we have a process to evaluate its integrity. If a TPR violates this Code, Branding Science will request immediate action and terminate the business relationship, if necessary.
Version 1.0, written by Chris Waters (Group CFO), April 2025
Change Record
| Version | Date | Description of change |
| 1.0 | 13th May 2025 | Policy issued |