Compliance and Anti-Corruption Policy
Introduction
At C2Outcomes, we are committed to maintaining the highest standards of ethical behaviour and integrity in all our business practices. This Compliance Policy serves as a guideline for all employees, directors and partners involved directly or indirectly in our operations, ensuring that our conduct reflects our core values and respects the legal frameworks of the regions where we operate.
Purpose
The purpose of this policy is to outline the ethical guidelines that govern our actions within the company and in dealing with external stakeholders. Our aim is to foster an environment of integrity, responsibility and transparency that supports our mission to promote research and development in the health field.
Commitment to ethics and integrity
Ethical standards: All employees and partners are expected to behave according to the highest ethical standards, promoting honesty, integrity and fairness in all aspects of our business.
Compliance with laws: We strictly comply with the laws and regulations of each country in which we operate, ensuring that all business practices are legal and ethical.
Conflict of interest: Employees must avoid any conflict of interest with the company or our clients. Any potential conflict must be reported immediately to the compliance officer.
Anti-discrimination: We are committed to providing a workplace free of discrimination and harassment. All employees are expected to treat others with respect and dignity.
Code of Conduct
Professional conduct: All team members are expected to act professionally and ethically at all times, upholding company standards and working towards our collective goals.
Confidentiality and privacy: Protecting the confidentiality of our data and that of our clients is fundamental. Employees must ensure that confidential information is handled appropriately and shared only in accordance with company policies.
Responsibility: Employees are responsible for their actions and must ensure that their behaviour is in line with this policy. Any deviations from this policy must be reported through the appropriate channels.
Compliance mechanisms
Training and awareness: All employees will receive regular training to ensure they are aware of their ethical obligations and compliance requirements. New hires will receive training as part of their onboarding process.
Monitoring and enforcement: Compliance with this policy will be regularly monitored and enforced through internal audits and checks. Non-compliance will be treated seriously and may lead to disciplinary action.
Reporting and whistleblowing: We encourage an open environment in which employees feel safe to report unethical behaviour or policy violations without fear of retaliation. All reports can be made anonymously and will be thoroughly investigated.
Review and updates
This policy is reviewed every two years to ensure that it remains relevant and effective in meeting our ethical and legal obligations. Changes to the policy are made in consideration of new legal requirements, industry standards or internal business changes.
Contact information
If you have any questions or concerns regarding this policy, or to report a possible violation, please contact us:
This Compliance Policy is the cornerstone of our operational integrity at C2Outcomes. We expect every member of our team to uphold these standards as part of their daily responsibilities and their commitment to ethical conduct.
Anti-corruption
Introduction
At C2Outcomes, we maintain an unwavering commitment to ethical practices and integrity in all aspects of our operations. This Anti-Corruption Policy describes our firm stance against any form of corruption and bribery, emphasising our dedication to legal and ethical conduct. We adhere to all applicable national and international anti-corruption laws on a daily basis, ensuring that our business operations promote transparency and accountability.
Scope of the policy
This policy applies globally to all individuals associated with C2Outcomes, including employees at all levels, directors, officers, consultants and representatives of third parties. This policy is applicable in all countries where C2Outcomes operates, ensuring consistency and compliance across our global footprint.
Applicable legislation
Our operations are guided by various laws and regulations, including but not limited to the following:
The Foreign Corrupt Practices Act (FCPA) of 1977
The UK Bribery Act 2010
The Brazilian Anti-Corruption Law No. 12.846/2013
Other relevant local laws in the countries where we operate
Definitions
Compliance: Adherence to laws, regulations and the company's ethical standards.
Corruption: Acts involving the misuse of power for private gain, including bribery and embezzlement.
Bribery: Offering, giving, receiving or requesting something of value to influence an official action or business decision.
Due Diligence: The process of investigating and evaluating a company or individual prior to a business engagement.
Prohibited behaviour
No employee or associated party should engage in bribery or corrupt practices in any form.
Facilitation payments must not be made to expedite or guarantee the execution of routine government actions.
No gifts, hospitality or undue expenses should be offered to influence business results.
Responsibilities
All employees and associated parties are expected to comply with this policy, report any possible violations and attend regular training sessions.
Management is responsible for applying this policy, providing the necessary resources for its implementation and taking action in the event of violations.
Whistleblowing and reporting irregularities
Employees and third parties are encouraged to report any suspicious activities or violations of this policy through the established channels, without fear of retaliation.
C2Outcomes guarantees confidentiality and protection to all whistleblowers.
Enforcement and sanctions
Violations of this policy will result in disciplinary action, which may include dismissal, legal action and fines, depending on the seriousness of the misconduct.
Regular audits will be carried out to ensure compliance with this policy.
Training and communication
Regular training on anti-corruption practices will be offered to all employees and necessary third parties.
This policy will be communicated to all employees and relevant stakeholders to ensure widespread understanding and implementation.
Review of the policy
This policy will be reviewed every two years or as necessary to reflect changes in legislation, corporate governance standards or internal business practices.
Contact for enquiries:
If you have any questions or wish to report a concern, please contact our Compliance Department at infor@c2outcomes.com.br.
C2Outcomes is committed to operating with the highest standards of integrity and expects all associated parties to follow our Anti-Corruption Policy. This commitment goes beyond compliance with the law and incorporates the ethical principles that define our corporate culture.