We conduct our operations with honesty, integrity and openness. We shall similarly respect the legitimate interests of those with whom we have relationships.We strive for continuous improvement in our performance, measuring results carefully, and ensuring that integrity and respect for people are never compromised.We are deeply committed to meeting the needs of our customers, and we constantly focus on customer satisfaction.We are dedicated to providing opportunities for leadership at all levels in our organization.We play an active role in making community a better place to live and work, knowing that its ongoing vitality has a direct impact on the long-term health of our business.We are aware that to be a successful company, we must work together, frequently transcending organizational and geographic boundaries to meet the changing needs of our customers.

Our Company

We are committed to pursuing sound operations and performance goals while maintaining integrity in all that we do. We will operate in the best interests of the Company, and exercise care in the use of our assets and resources.

To protect the best interests of the Company, we will:

• Protect patents, trademarks and other intellectual property;
• Keep accurate and complete books and records, and maintain an effective system of internal controls over our operations;
• Retain Company records to comply with our obligations;
• Make appropriate use of company resources and keep our information systems, and networks secure;
• Safeguard confidential, proprietary and personal information; and
• Avoid conflicts of interest.

 

Patents, Trademarks and Copyrights

Protecting Samarth’s intellectual property is essential to maintaining the Company’s competitive advantage. Samarth’s intellectual property includes its patents, trademarks, trade secrets and copyrights, as well as scientific and technical knowledge, know-how and experience developed in the course of the Company’s activities. You also must respect the intellectual property of others. Unauthorized use, theft or misappropriation of third-party intellectual property (including unlicensed software) may result in significant fines, lawsuits or criminal penalties for the Company and you.

Financial & Other Records

Accurate business records are essential to the management of the Company. They also help your company fulfil its obligation to provide full, accurate and timely financial and other disclosures to the relevant regulators. All of your company’s books, records and accounts must fully and accurately reflect the Company’s business transactions.

Use of Company Computers and Resources

Samarth supports information systems and networks to help employees work as effectively as possible. When used inappropriately, Samarth’s data and systems may be exposed to substantial risk.

To ensure the security and integrity of information systems:

• Only authorized software and procedures may be used.
• Your password must never be shared except for a valid business reason (such as
• Technical support), after which it must be changed within 24 hours.
• Company’s business information may only be shared with authorized parties subject your superiors approval, and only by using Samarth e-mail.
• Unauthorized devices, such as home computers, may not be used to transmit, store or work on Samarth proprietary information.
• You are accountable for the use and security of the Company’s telecommunication and information assets.

 

Confidential and Proprietary Information

The products, services, ideas, concepts and other information we produce on a daily basis are important proprietary assets for our Company, including marketing plans, sales data, clinical and medical data, customer and employee records, manufacturing techniques, pricing information and information about business development opportunities.

Various laws enable us to protect these assets. It is important that Samarth protect and prevent inappropriate or unauthorized access to or disclosure of this information, as well as third party information provided to Samarth.

Help protect confidential and proprietary information by following these principles:

• Be careful when using electronic means of storing and sending information.
• Do not disclose information to third parties, including business partners and vendors, without appropriate authorization and any required confidentiality agreements. If in doubt, check with your manager and the CFO.
• Do not discuss confidential information in public places where others may overhear.
• Beware of informal telephone or email requests from outsiders seeking information (commonly known as “phishing”).

 

Conflicts of Interest

A conflict of interest arises when you place your personal, social, financial or political interests before the interests of the Company. Even the appearance of a conflict can damage your reputation or that of the Company. However, many potential conflicts of interest can be resolved in a simple and mutually acceptable way.

While your company respects your right to manage your investments and does not wish to interfere with your personal life, you are responsible for avoiding situations that present—or create the appearance of—a conflict between your interests and those of the Company.

Any potential conflict of interest must be disclosed to and approved by your manager. Further, such approval be shared with Head-Human Resources.

The following are examples of potential conflicts of interest.

Personal Investments or Transactions

Conflicts of interest may arise if you or a family member:

• Has a substantial financial interest in a Samarth supplier, competitor or customer;
• Has an interest in a transaction in which it is known that Samarth is, or may be, interested;
• Takes advantage of Samarth’s corporate opportunities for personal profit; or
• Receives fees, commissions, services or other compensation from a Samarth supplier, competitor or customer.

 

Outside Business and Other Interests

A conflict of interest exists if your outside business or other interests can affect your objectivity, motivation or performance as a Samarth employee.

A second job or affiliation with a Samarth competitor is not allowed. Any pecuniary relationship with a Samarth customer, supplier or provider of goods or services is discouraged, but may be allowed with proper approval. Even when such relationship is allowed, employees are still bound by all confidentiality agreements with Samarth and all Samarth policies and procedures relating to confidential or inside information.

Gifts and Other Items of Value

The Company prohibits you and your immediate family from giving and accepting gifts, services, perks, entertainment, discounts, loans or other items from those who are doing business or seeking business with the Company.

Our Market Environment

We will compete lawfully and ethically in the marketplace. We will act responsibly in our relationships with healthcare professionals, patients, consumers, hospitals, academics, governments, regulatory entities, business partners, customers, suppliers and vendors. We will provide innovative products to our customers, and we will be honest and fair in all our business dealings.

We will:

• Comply with all healthcare laws and regulatory requirements;
• Inform healthcare professionals, consumers safety information for our products;
• Market products and interact with healthcare professionals honestly in accordance with laws and regulations;
• Monitor the safety, performance and quality of our products;
• Interact ethically and in good faith with regulators and business partners;
• Gather business intelligence properly.

We will not:

• Offer or make illegal payments to government officials or business partners, directly or through intermediaries; or
• Offer or accept inappropriate items of value, including gifts or entertainment.

 

Healthcare Laws and Regulatory Requirements

Your Company is subject to many rules and regulations designed to protect patients and consumers, improve the quality of medicines and healthcare services, and help eliminate fraud and improper influence on medical judgment.

Your Company follows all laws and regulatory requirements governing the development, manufacturing, distribution, marketing, government contracting, sale and promotion of our products.

You must be familiar with the SOPs that apply to your business and your role. By following SOPs, you will ensure your compliance with all laws and regulations relating to the conduct of our business.

Promotional Activities and Interactions with Healthcare Professionals

Regulation of product promotion directly affects our customer relationships. All employees must follow Company’s policies on promotional activities and interactions with healthcare professionals applicable to ensure compliance with MCI and CBDT guidelines.

All promotional materials and communications must be accurate, not misleading, and compliant with all applicable medical, legal and regulatory standards, including any applicable standards addressing substantiation, scientific rigor and fair balance.

Strict regulations govern not only our promotional activities but also our educational and commercial relationships with healthcare professionals, including our interactions with physicians, nurses, pharmacists and others who administer, prescribe, purchase or recommend prescription medications. All interactions with healthcare professionals must be guided by applicable:

• Laws, regulations, and other industry standards;
• National and regional industry association codes;
• Company policies and procedures.

 

Marketing Integrity

We are committed to fair competition as a matter of corporate conduct. We abide by all laws that apply to our marketing activities. Under these laws, it is illegal to use unfair methods of competition or unfair or deceptive acts or practices in commerce, such as:

• False or misleading promotion, or any other form of misrepresentation made in connection with sales;
• Bribery of competitors’ or customers’ employees or of healthcare professionals; and
• Unfair comments about competitors’ products.

Employees in sales, marketing, medical and regulatory functions must be familiar with company policies and procedures on labelling, promotional programs, product sampling, and medical positioning of the products.

Monitoring the Safety, Performance and Quality of Our Products

At Samarth, patient safety is utmost priority. Understanding a product’s safety profile, as well as its quality and performance characteristics, is not only essential but fundamental to our existence. These components are extensively benchmarked and monitored during BA/BE studies of our products with Innovator’s products. Further, degradation studies of the products are conducted on continuous basis to ensure efficacy of the products during its shelf-life. Also, compatible studies are conducted to ensure inter / intra drug reactions (contra indications).

Our field employees are responsible in ensuring reporting of adverse events, quality complaints, since we have a legal obligation to track and report product quality complaints to regulatory authorities and which may lead to product recall. Further, healthcare professionals require quick feedback from the company on all product complaints.

Anti-Bribery and Anti-Corruption

Your company prohibits its employees or anyone acting on your company’s behalf from offering, giving, soliciting, accepting or receiving a bribe.

Government Officials

No employee nor anyone acting on your company’s behalf may ever make a payment or provide a benefit that is intended to improperly influence—or even appears to improperly influence—a government official, or to gain an unfair business advantage.

We must be particularly sensitive to bribery and corruption issues because governments are often both the regulator of our products and a major customer.

We also use the services of healthcare professionals and scientists, many of whom are employees of public institutions and may be considered government officials.

Business Intelligence

In today’s business environment, we have access to a great amount of information about other companies, their products and services, some of which is non-public.

You are free to gather intelligence about companies from public sources such as their websites, published articles, price bulletins, advertisements, brochures, public presentations and customer conversations. You also may contract with an outside vendor to gather business information.

Business information about other companies may only be collected and used ethically and in a way that does not violate any laws or confidentiality obligations. You must never use, or ask any third party to use, unlawful or unethical means such as misrepresentation, deception, theft, spying or bribery to gather information.

Core Value - Integrity

“Integrity is doing right things when no one is watching”.

Performing with integrity means setting the right priorities and delivering on our commitments while adhering to Company’s Values and SOPs. We can do this by:

• Taking responsibility and holding each other accountable;
• Raising concerns and asking questions;
• Making the right decisions even when the decisions are difficult; and
• Maintaining Samarth’s quality standards in everything we do and everywhere we operate.

At Samarth, performance with integrity is not only what we do—it’s our DNA.

Any violation of a law or Company policy can result in disciplinary action, including termination of employment, particularly if you:

• Knowingly and intentionally violate the law or policy;
• Direct others to violate the law or policy;
• Fail to cooperate in a Company investigation of possible violations;
• Retaliate against another employee for reporting a concern or a violation; or
• Fail to effectively monitor the actions of subordinates.

 

Integrity is at the core of our company’s identity and reputation, and we are all responsible for performing with integrity in everything we do. We are also responsible for raising concerns about risks to the company—ideally, before these risks become actual problems.

If you reasonably believe that an employee has violated or may violate a law or company policy, you have a duty to report that information immediately to your manager, another manager, or Human Resources. Your Company believes in Open Door, anti-retaliation and confidentiality policies to protect employees.

Retaliation against any employee who in good faith seeks advice, raises a concern or reports misconduct is strictly prohibited. Whenever you are in doubt, it is best to raise your concern.

Non-compliance can pose serious risks for Samarth, customers, patients, and employees. By raising concerns, you give management the opportunity to address potential problems and protect the Company. For example…

Consequences for Company:

• Prosecution, fines and other penalties for the improper conduct of its employees
• Disclosure to government regulator
• Loss of business
• Damage to Samarth’s reputation, trade and customer relations, or business opportunities

 

Consequences for Patients, Customers and the Public:

• Compromised product safety or efficacy
• Environmental risk
• Loss of good faith and trust in dealings with Samarth

 

Our Employees

Your company is committed to treating its employees and potential employees with fairness and respect. We believe in cooperation, teamwork and trust. Hostility and harassment are not tolerated.

To create and maintain a safe work environment where people are treated respectfully and fairly, we will:

• Treat employees fairly;
• Abide by all health, safety and employment related laws and regulations;
• Promote a positive and harassment-free work environment; and
• Protect the health and welfare of all employees.

We will not:

• Engage in any form of discrimination, harassment or retaliation;

 

Anti-Retaliation Policy

Retaliation against any employee who in good faith seeks advice, raises a concern or reports misconduct is strictly prohibited. If any individual, regardless of his or her role in Samarth, retaliates against an employee who has truthfully and in good faith reported a potential violation, Samarth will take appropriate action—even if it later turns out that the employee was mistaken in reporting the matter originally.

 

Discrimination or Harassment

Samarth values a work environment that is free of verbal or physical harassment.

This includes any unwelcome comments or actions regarding creed, religion, age, marital status, related medical condition or physical disability. This policy applies to conduct that: creates an intimidating, hostile or offensive working environment; or unreasonably interferes with an individual’s work performance.

 

Reporting Discrimination or Harassment

Employees who engage in acts of harassment or discrimination are subject to corrective action that may include termination of employment. Managers are responsible for maintaining business units that are free of harassment and discrimination. Samarth is also committed to providing an environment that is free of retaliation.

Samarth promotes open communication throughout the Company to resolve questions, concerns, problems or complaints involving discrimination or harassment. If you experience or are aware of any discrimination or harassment, you can:

• Talk to your immediate superior or Head- Human Resources.

 

Our Public Policy

Protecting the Environment and Health and Safety (EHS)

Samarth strives to protect the environment and the health and safety of its employees the communities in which we operate. Samarth is responsible for setting appropriate health and safety standards at all its facilities and offices.

All employees are expected to take responsibility for EHS compliance, and to play your part you must:

• Comply with the programs and procedures designed by your management to meet your company’s EHS standards and local regulatory requirements;
• Be actively involved in highlighting issues that could potentially impact the environment, health or safety;
• Report concerns about potential non-compliance to your manager.

 

Government Investigations: Requests for Information or Facility Visits

As a matter of policy, Samarth will cooperate with all government authorities in connection with requests for information or facility visits.

The CFO must be notified of all non-routine government requests for information or facility visits. The CFO will provide all necessary legal representation of the Company in such situations and will determine what information needs to be provided to the relevant government points of contact in each case. Although the Company and our employees may not appear to be the subject or target of an inquiry, non-routine requests may expose Samarth or individual employees to civil or criminal liability. If you are contacted by any government authority, with regard to a non-routine request for information or a facility visit, you must immediately notify the CFO or your business unit head to provide inspection support for your site.

In addition, physical searches and raids by government authorities, as well as non-routine regulatory inspections that result in “critical” adverse findings or formal warnings, which must be notified immediately to the CFO and to the CEO.