Supplier Code of Conduct

1. Overview and Purpose

PODS Pharma is committed to the highest standards of business ethics and integrity wherever it operates. Our continued success depends upon employees, vendors, and other business partners conducting themselves with honesty and integrity when acting with or on behalf of PODS Pharma.

This Supplier Code of Conduct sets out the minimum standards that vendors must comply with in their dealings with PODS Pharma. Vendors are encouraged to exceed these minimum requirements. Vendors must also comply with any additional obligations contained in purchase orders, contracts, or other agreements, as well as other applicable PODS Pharma policies and procedures.

2. Scope

  • Vendors, distributors, agents, representatives, third-party intermediaries, suppliers, and subcontractors
  • Their employees, directors, and officers

All Vendors must comply with this Code in order to conduct business with PODS Pharma and its subsidiaries or affiliates.

3. Compliance with Laws and Regulations

  • Comply with all applicable local, national, and international laws and regulations in the jurisdictions where they operate.
  • Abide by operational regulations including UK GMP requirements under MHRA, and equivalent EU or global standards.
  • Where local law conflicts with international standards (ILO Conventions or Universal Declaration of Human Rights), comply at minimum with local law and work towards higher standards where possible.

4. Supply Chain Sustainability

  • Provide supply chain transparency and mapping
  • Assess supplier performance and risks
  • Support diversity through inclusive sourcing practices
  • Contribute to sustainable development in communities

5. Anti-Bribery, Anti-Corruption, Trade, and Competition Compliance

5.1 Anti-Corruption and Bribery

  • Comply fully with the UK Bribery Act 2010 and other applicable anti-corruption laws.
  • No improper payments or benefits to public officials or business partners to gain unfair advantage.
  • Comply with PODS Pharma’s Anti-Bribery and Corruption Policy.

5.2 Trade Compliance

  • Comply with all trade/customs regulations.
  • Label goods with country of origin.
  • Ensure commercial invoices/documentation meet customs requirements.
  • No exports in violation of the UK Export Control Act 2002 or Export Control Order 2008.

5.3 Facility and Supply Chain Security

  • Implement adequate security controls at all facilities.
  • Meet standards equivalent to AEO certification if possible.
  • Keep documented proof of compliance.

5.4 Anti-Counterfeiting

  • Report any counterfeit, stolen, diverted, or unauthorized products immediately.

5.5 Conflict Minerals

  • Comply with EU Conflict Minerals Regulation (2017/821) and UK guidance.
  • Conduct due diligence on conflict minerals origin and cooperate with PODS Pharma's inquiries.

5.6 Boycotts

  • No participation in boycotts unless officially sanctioned by the UK Government, EU, or UN.

5.7 Competition Law

  • Comply with Competition Act 1998, Enterprise Act 2002, and equivalent competition laws.

6. Integrity

  • Business Records: All records must be accurate and compliant.
  • Deal honestly and transparently with all regulators.
  • No speaking on behalf of PODS Pharma without written authorization.
  • Avoid gifts or hospitality that could improperly influence PODS Pharma staff.
  • Avoid conflicts of interest (e.g., financial interests in the Vendor).
  • No insider trading.
  • Maintain contingency/crisis management plans.
  • Animal testing should be humane and minimized.

7. Labour Practices and Human Rights

  • Respect Modern Slavery Act 2015, Equality Act 2010, Employment Rights Act 1996.
  • No child labour.
  • Pay fair compensation.
  • Limit working to 60 hours/week, provide rest days.
  • No harassment or abuse.
  • Support diversity and inclusion.
  • Respect freedom of association and trade unionizing.
  • Employ only legally authorized workers, do not retain worker documents.
  • Maintain accurate payroll and employment records.

8. Environmental, Health and Safety (EHS)

  • Comply with Health and Safety at Work Act 1974, Environmental Protection Act 1990, UK/EU REACH Regulation.
  • Develop risk identification and mitigation systems.
  • Provide safe and healthy workplace and accommodation.
  • Prepare for emergencies and operate sustainably.

9. Confidentiality, Data Protection, and Privacy

  • Safeguard PODS Pharma’s confidential information.
  • Comply with UK GDPR and Data Protection Act 2018 when handling personal data.
  • Respect privacy rights of employees, patients, and third parties.

10. Records Management

  • Maintain records according to UK law.
  • Dispose of records securely when no longer required.
  • Return or destroy PODS Pharma documents upon request unless legally required.

11. Promotion and Sale of PODS Pharma Products

  • No promotion prior to approval from MHRA or other regulator.
  • No promotion for off-label use.
  • Report adverse events or complaints immediately.

12. Social Media

  • Train employees on responsible social media use.
  • No misrepresentation or defamatory/offensive posts.
  • No communications harmful to PODS Pharma’s reputation.

13. Government Lobbying

  • No lobbying on behalf of PODS Pharma without written approval from Head of Government Relations.

14. Subcontractors

  • Only engage subcontractors under written agreements.
  • Subcontractors must comply with this Code and be trained.
  • Vendor must provide details of subcontractor staff upon request.

15. Reporting and Investigations

  • Establish whistleblowing channels.
  • Protect employees under Public Interest Disclosure Act 1998 (PIDA).
  • Investigate reports and take corrective action.
  • No retaliation against whistle-blowers.

16. Quality Standards and Change Control

  • Operate a quality management system.
  • Comply with Supplier Quality Agreements.
  • Notify PODS Pharma of product changes.
  • Respond to Supplier Corrective Action Requests (SCARs).
  • Permit audits of facilities and records.

17. Training, Compliance Monitoring, and Policies

  • Train employees on this Code.
  • Monitor compliance.
  • PODS Pharma may suspend/terminate business for non-compliance.
  • Vendors may be required to formally acknowledge compliance.

18. Reporting Questionable Behaviour and Possible Violations

  • Raise concerns with relevant PODS Pharma contact.
  • If not appropriate, use Business Conduct Line or online platform.
  • Vendors are protected against retaliation for good faith reporting.

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