1. SCOPE

The scope of this policy is to ensure that neither DEMO’s staff nor any third party acting on DEMO’ s behalf gives, offers or promises payments, gifts or anything of value directly or indirectly to any natural person so as to influence that natural person to conduct or maintain business with DEMO or gain an improper business advantage for DEMO. The exercise of influence of the specific natural person may include, among other things, his/hers involvement in compensation committees, pricing committees or medicines’ approval committees or solely the controlled prescription of DEMO products.

2. RECIPIENTS

This policy concerns all DEMO’s staff.

3. DEFINITIONS/ABBREVIATIONS (OPTIONAL):

1. Bribery: Giving or receiving a bribe, directly or indirectly, with the intention of influencing the recipient to serve a purpose favorable to the person providing the bribe.
2. “Improper” payment: Anything of value that can influence a government/public official or any other powerful person to secure an advantage to DEMO’s business in exchange for a payment.
3. Corruption: Corruption is the abuse of the power entrusted to a person for his own benefit.
4. Government or Public Official: Natural Person who either receives part of his salary from the state or fulfills a state function with or without remuneration.

4. GENERAL

1. Bribery of any kind to any natural person is strictly prohibited. No employee of the Company is allowed to give, promise or receive from any natural person any improper payment, gift or any other item of value.
2. It is prohibited to pay, promise to pay or offer any item of value or any other type of benefit to any government or public official.
3. Natural Persons or Organizations acting on behalf of the Company must follow the same strict rules. Commission, consulting fee or any other payment to any third party must not be used as a means of bribery or other improper payments.
4. All reports of the Company’s financial data should be accurate, appropriate and reflect the actual data.
5. There must not be, for any reason whatsoever, any false, artificial or misleading entry in the Company’s books or records. Any transaction other than that described in the relevant documents proving its validity and conformity is prohibited.
6. It is prohibited not to register any funds or assets in the relevant books and records of the Company.
7. No employee has the right to sign, submit or permit others to sign or submit on behalf of the Company any document or statement which the employee himself knows or has reason to suspect is false or misleading.
8. Discounts and refunds provided in connection with sales transactions involving the Company’s products are prohibited from being used as a means of bribery. Such payments and benefits must be lawful, accurately substantiated by appropriate data recorded in the Company’s financial records.
9. Supply/Provision of Services: The Company may address Health Professionals for the provision of consulting and other services directly related to their specialty. Any relevant cooperation/service provision must meet the criteria set out in the Company’s relevant policy.
10. Funding Health professionals’ Attendance to Scientific Events: Health professionals and organizations have the possibility to request financial or other support from DEMO for various types of scientific events. The Company may fund Health Professionals’ attendance to scientific events, organized either by thirdparty organizations or by the Company itself and offer hospitality, pursuant to the provisions of the law, the regulations of the SFEE Code of Ethics, provided that the criteria defined in the Company’ s relevant policy are met.
11. Grants and Donations: Grants or donations can only be made to organizations and not to natural persons, in compliance with the provisions of the law, the regulations of the SFEE Code of Ethics provided that the criteria defined in the Company’s relevant policy are met.

5. FREQUENCY

This policy is applied in all cases and in particular during the Company’s contacts with public officials or other similar stakeholders. Training in the policy, as well as review of its content, takes place every three (3) years or even earlier if this is deemed necessary.

6. RESPONSIBILITIES

All DEMO employees, agents and representatives are prohibited from taking or directing anyone to take any illegal action as described above. All DEMO employees, agents and representatives must comply with all of the above requirements.
Failure to comply with this policy may cause significant damage to DEMO’s reputation and financial position.

7. PROCEDURE

All DEMO employees must respect and apply all the above principles in their daily activities and especially during their contacts with public officials or other stakeholders. It should also be ensured that any third party who cooperates with or provides services
to DEMO respect and follow the aforementioned principles.