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Compliance, Ethics and Transparency

At Grünenthal, we have a responsibility to act with integrity and to conduct all of our research and business activities in compliance with applicable laws and regulations. Building trust by maintaining the highest ethical standards gives confidence to our stakeholders – including patients, customers, employees, partners, suppliers, investors and the communities we serve.

Our culture and our compliance system provide a clear framework for our actions and are built around our Code of Conduct.

Our Compliance Organisation is deeply anchored into our business, and Compliance Officers are members of various decision-making bodies across the organisation and in all of our major affiliates. Their independence is maintained via a direct reporting line into the Global Compliance Officer, who regularly reports to the Executive Board and the Advisory Board.

Our global Compliance framework is brought to life through ongoing dialogue. This includes face-to-face training and workshops, as well as online training sessions and day-to-day consulting for our colleagues. The compliant management of our business partners forms part of this framework. We also offer a 24-hour Ethics Helpline that is open to anyone who has questions, concerns or doubts.

Compliance
The Grünenthal Code of Conduct states our commitment to high ethical standards. Everybody in our organisation has the responsibility to live up to this framework in their daily work and needs to sign our Code of Conduct when joining Grünenthal.
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We are committed to ethical business practices – and our business partners must also adhere to all applicable laws and regulations. To ensure this, we established our Code of Conduct for Business Partners, which must be signed before formally entering into a partnership.
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We depend on our employees – and also on third parties – to raise any concerns they might have. We encourage everyone to report any questions, doubts or suspicions personally or anonymously through our Ethics Helpline, which is a confidential internet-based platform that allows 24/7 reporting.
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Ethical Business
We share the broad consensus within the pain community that the opioid crisis in some countries needs to be addressed with high urgency. Grünenthal’s Charter on the Responsible Use of Opioids sets out our commitment to exploring and endorsing measures that minimise the risk of inappropriate and illegitimate use of prescription opioids – while striving to ensure that individual patients with a clear need for opioid-based pain relief are not denied access.
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Grünenthal is committed to conducting business in a legal, ethical and honest manner. We do not tolerate any corrupt activities. A breach of anti-corruption laws can result in severe consequences for both the company and the individual involved.
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We handle all personal data responsibly. We conduct all of our data processing activities in line with applicable legal standards such as the GDPR, and we also adhere to the principles laid out in our Digital Ethics Charter and Data Protection Policy.

Grünenthal respects internationally adopted human and labour rights. We practice a zero-tolerance policy for child labour and forced labour. We report our efforts in this context within our company statement responding to the UK Modern Slavery Act.

Transparency
Grünenthal will share clinical information that is necessary for conducting legitimate research, serving patients’ safety and improving public health. We have publicly committed to the Principles for Responsible Clinical Trial Data Sharing that were issued in January 2014 by the European Federation of Pharmaceutical Industries and Associations (EFPIA) and the Pharmaceutical Research and Manufacturers of America (PhRMA).
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Grünenthal is a member of the European Federation of Pharmaceutical Industries and Associations (EFPIA) and supports the EFPIA Disclosure Code. We are committed to publishing information about our collaboration with healthcare professionals (HCPs) and healthcare organisations (HCOs) to demonstrate that we interact with these stakeholders in an ethical and transparent way.
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All interactions and transfers of value are disclosed in line with local regulations. These disclosures are aligned with either the EFPIA Disclosure (Transparency) Code of Conduct, local pharmaceutical codes or national legislation implemented by organisations such as healthcare authorities. The underlying rationale and methodology follow a coherent concept.
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