TMB Code of Conduct
- TMB Good reputation based on its integrity in business
- In all Interactions with our stakeholders we are committed to doing the right things.
- All employees & affiliates of TMB must comply with TMB CoC regardless of their location and nature of work.
- TMB code of conduct is designed to guide our business behavior & provides practical guidance to meet with our four essential pillars.
- In case of doubts about the correct behavior , we must seek help & advice.
- Adherence to TMB Code of Conduct is essential for employment .Each employee must read ,understand get trained & comply with it.
- TMB does not tolerate violations of TMB Code of Conduct and is fully committed to handling noncompliance cases adequately . Employees must be aware that such violations can have serious consequences for the company & for themselves and may lead to termination.
- Regular interactive face to face trainings have been developed to help explaining the importance of integrity in business covering the key messages of TMB Code of Conduct.
Innovation & Quality
We strive to the highest standard of quality in Licensing, Commercializing , Storage & Distribution.
Quality Standard & Good Practices
TMB is committed to complying with Legal & Regulatory requirement, Internationally recognized good practices.
Information & Marketing
TMB interactions with Healthcare professionals and Healthcare organization are aimed at exchanging scientific information that can help optimize the use of our marketed products These interactions are based on high standards of integrity, TMB is committed to complying with all applicable laws , regulations , industry codes & standards relating to good marketing practices.
Conflict of Interest
As TMB employee , we must avoid situations where personal interest conflicts or even appear to conflict , with the interest of TMB Associate must disclose actual or potential conflict of interest to their direct manager . Newly hired associates are requested to disclose any actual or potential conflicts of interests before they begin employment.
Gifts & Entertainment
We must not give or accept any gifts or entertainment that could raise any concerns regarding our personal integrity or TMB’s integrity and independence.
Business Integrity
It means first and foremost that we adhere to all applicable laws and regulations as well as to the high integrity standards set by TMB.
Bribery & Improper advantage
TMB rejects all forms of corrupted business behavior , such as bribery (Public , Private , active & passive) fraud and the granting of improper advantages.
Competition Laws
Also referred to as anti trust laws are designed to protect competition TMB founders or employees involved in a tender process must be aware of and comply with the applicable tender law regulations. Transparency must be maintained throughout the procurement cycle by adhering to applicable former procedure.
Data Privacy
TMB is committed to respecting data privacy and has developed principles that must be consistently applied when processing personal data within ISM & by its business partners
Accurate reporting & accounting
We ensure that any data , information or record which we create , or for which we are responsible , are true & fair . We must never make a false or misleading statement or entry in any report , record or expenses claim.
Taxes
TMB founders are committed to comply with the tax laws in any country where we operate.
Employment at TMB
We encourage and build a culture of mutual respect with dignity and integrity , where we attract an develop highly talented , engaged and diverse employees who are empowered to deliver excellent performance.
Discrimination & Harassment
TMB is committed to fair and equal treatment of all employees including equal opportunities for development and promotion, We do not tolerate any form of discrimination ( race , gender , religion ) or harassment in the work place.
Safety, Security & Health environment
TMB operations are conducted in compliance with applicable health security , safety and environmental laws regulations , company standards and best practices . We take all reasonable and practical steps to ensure that we provide a safe secure , Healthy & clean working environment
Confidential Information
We respect the confidential information belonging to partners and third parties any exchange of information is subject to the signing of a confidentiality agreement . Any (paper , electronic , audio/video , etc...) , that TMB employees create or receive in the course of their business are valuable assets for TMB interest.
Stakeholder Engagement
Transparent & Constructive dialogue with our stakeholders is crucial to improving our ability to create sustainable value & growth. It helps us to understand how to serve patients & physicians . Recognizing that our stakeholders play an important rule in our overall journey of success, we establish relationships with these who provide the best overall value , and who share our commitment to quality , service, diversity , reputation & ethical business practices.
Government Officials
TMB believes that a proactive, honest , transparent & responsible dialogue and engagement between government officials & private sector is a fundamental aspect of good public governance.
• All TMB employees working with government officials are expected to strictly follow our ethical business practices.
Compliance Responsibilities
TMB has established a WAY WE WORK program (WWW) which we are committed to implementing & enforcing. The WWW forces on prevention, detection and responding to noncompliance behavior.
Addressing Non-Compliance
TMB is fully committed to handling non-compliance cases adequately by: 1. Taking all allegations seriously 2. Investigating allegations efficiently and in time manner 3. Assessing the facts objectively and impartially 4. Taking adequate corrective measures in case substantiated
TMB on behalf of principle may interact with patients , patients advocate , caregivers, and patient organizations to understand perspective or to provide information on disease and their treatment in order to improve patients outcomes, affordability and access to medicine.
All Interactions must be ethical , transparent , based on mutual respect and maintain the independence of the patient.
All interactions must always put patients first, treat patient information with respect and protect confidentiality.
Patients, advocates, caregivers and patients' organizations must not be expected to endorse, promote or recommend any product or be involved in any product promotional activities.
Patients, patients’ advocates, caregivers & patient organizations must have a primary point of contact from Principle's Patients Relations, Communications, Public Affairs, Medical or similar noncommercial function.
Patients Support Programs (PSPs)
• PSPs are programs that involve interactions with patients or caregivers implemented by TMB Or TMB’s partners For example: use of call center to manage patient communications , disease awareness programs, or other activities to support patients for safe and proper use or administration of a product , information on co-payment ... Etc • PSPs are important to help patients manage their medications , disease outcomes (adherence support, education, emotional support).
PSPs MUST HAVE
1. Legitimate need and purpose (match our 4 Pillars)
2. parameters that describe what patients are within the scope
3. Clear Purpose ; to protect the rights and privacy of the patient and in compliance with patient informed consent and the requirement of Adverse event reporting standards .
PSPs SHOULD NOT BE
designed or intended to encourage the use of principles’ product or to encourage the use in a manner that is inconsistent with approved product label.
Data gathering or clinical research, the collection of patients' information and data in any organizational or patients programs must be protected , it must be reviewed to verify and take the approvals from local health authorities before enrolled in clinical research and aligns to to be applicable with regulations and must be fully separated from sales function
Patients Data must be collected , used and disclosed in accordance with applicable privacy laws
• WWW focuses on prevention, detection and responding to non-compliance behavior by comprehensively involving people, principles, policies & processes.
• TMB believes that the sense of responsibility of each and every employee is the basis for compliance . Thus we must constantly and adequately identify, assess and manage the compliance risks that fall within the sphere of our business responsibilities.
• TMB is committed to providing adequate training for all employees which enables them to meet their responsibilities.
• The Compliance Officer also serves as a contact for employees, business partners and customers on issues relating to the implementation of and compliance with TMB CoC.
• The Compliance Officer responsibilities are: Ensuring that employees know where employees can ask for help and advice if they have doubt Coordinating local compliance initiatives and trainings Supporting & Conducting compliance monitoring and controls Supporting Business in the local integrity risk management processes Supporting Business in handling of local non-compliance cases . Encouraging employees to speak up if they have a compliance concerns.