Ferring’s reputation and the trust and confidence of those with whom we do business are among our most vital corporate resources. Our company is committed to conducting its affairs in a uniformly ethical manner and pursuant to a standard of fundamental honesty and fair dealing. This standard requires adherence to all laws, regulations, and normal ethical practices that apply to the company’s business activities. Ferring adheres to the PhRMA Code when interacting with its customers and how it approaches its business. A copy of the PhRMA Code can be found on Ferring’s external website www.ferringusa.com by pulling down the “Values” tab and then the “Compliance Policies & Procedures” tab.
Areas of Potential Conflict:
- Holding a substantial financial interest in any enterprise with which the company has business dealings (e.g., competitors, suppliers, and customers). (Interest of less than $5,000 or that regardless of value, amount to less than one percent of an enterprise are not considered to be substantial);
- Accepting, directly or indirectly, from any vendor or supplier of services, any vacations, cash payment ($100 or more; other than reimbursement of reasonable out-of-pocket expenses), service, loan (except from banks or other financial institutions), or discount (except those offered to employees of the Company) by an employee or any member of an employee’s immediate family;
- Accepting gifts or other benefits of greater than nominal value per year (i.e. $200) from any vendor or supplier of materials or services.
Performance with Integrity – A Shared Responsibility
What does it mean to perform with integrity?
Performing with integrity means setting the right priorities and delivering on our commitments while adhering to Ferring’s values and the standards set forth in this guidebook. We do this by:
- integrating integrity into all that we do;
- holding ourselves personally accountable to high ethical standards;
- demonstrating leadership by fostering an environment focused on performance with integrity and accountability.
At Ferring, performance with integrity is not only what we do, it’s who we are.
Prohibition Against Retaliation and Protection of Anonymity
A crucial and all-important value at Ferring is maintaining an environment where people in all parts of the organization feel safe raising concerns and reporting suspected violations of applicable ethical and business standards or laws, rules, regulations or Ferring policies. Ferring prohibits any form of retaliation against any individual, who, in good faith, reports actual or suspected violations of applicable regulations, laws, guidance, or Ferring policy. Ferring personnel who retaliate against individuals who have reported an alleged violation will be subject to disciplinary action, up to and including termination. Ferring’s Compliance Officer, in coordination with the Human Resources Department, will investigate and track any and all reported instances of retaliation against Ferring personnel. In action, Ferring will protect the confidentiality of anyone reporting non-compliance information within the boundaries of the law.
Important Contact Information
ATTN: Compliance Office
100 Interpace Parkway
Parsippany, NJ 07054