Code of Conduct

Author / Prepared By: Francis Lawrence A. Lopez QMS Analyst
Reviewed by: Jhoedith D. Base QMS and Compliance Officer
Approved by: Julita O. Geronimo President & CEO

I. INTRODUCTION
Globo Asiatico Enterprises, Inc. (Company) is committed to maintaining the highest ethical standards and complying with all applicable laws and regulations in the conduct of its business in all parts of the world, whether such business is carried out through direct sales operations or distribution.

II. APPLICABILITY
This Code of Conduct applies to all directors, officers, and employees (collectively “Employees”) of the Company.

III. ASSOCIATED DOCUMENTS
• GAE-HRD-POL-009 Anti Corruption and Bribery Policy
• GAE-QMS-POL-010 Data Privacy Policy
• Human Resource and Administrative Services Employee Handbook

IV. GENERAL PRINCIPLES
    A. ANTI-BRIBERY AND CORRUPTION POLICY
Employees must comply with all applicable laws and regulations including, without limitation, anti corruption and anti bribery laws (GAE-HRD-POL-009, Anti Corruption and Bribery Policy). This means that no employee, officer, director or sub-distributor (if applicable) of the Company shall offer, pay, or authorize payment or the giving of anything of value to any customer, Healthcare Provider, government official, or any other third party, clients, for the purpose of obtaining any improper business advantage. For the purpose of this document, “improper” means unlawful, or with a corrupt purpose. “Anything of value” includes, but is not limited to:
• Cash
• Discounts
• Gifts
• Rebates
• Contracts
• Tickets and Entertainment
• Travel & Lodging
• Sponsorships
• Loans
• Employment promise
• Use of materials, equipment, software or facilities
• Grants and donations, support for research
• Special Favor
• Solicitation

“Healthcare Provider” shall mean an individual physician or other medical professional, a healthcare institution, or an administrator or any other person affiliated with a healthcare institution who may have influence on the decision to purchase, prescribe or use a product.

    B. BOOKS AND RECORDS
The Company must accurately record and maintain all transactions and expenses in the Company books, records and accounts in a timely manner and in reasonable detail in accordance with generally accepted accounting principles. False, misleading, incomplete, duplicated, inaccurate or artificial entries in the Company books and records are strictly prohibited. The Company shall keep complete and accurate records of general marketing and promotional activities.

    C. CONFLICTS OF INTEREST
The Company must identify, prevent, and, where contractually required, immediately disclose situations where there is an actual or perceived conflict of interest. These situations include, but are not limited to, employment of government officials by the Company having a government official as a shareholder, employment of or familial relationships with contracted third party employees, physician owned, or any other situation where it may appear that the Company decisions can be influenced by personal interests or relationships.

    D. TRAINING, EDUCATION AND CONFERENCES
The Company may organize events with a third party providers, suppliers, vendors, and subcontractors including Healthcare Providers to provide instruction, education and training to improve the quality of distribution services or to explain the safe and effective use of products. Such events are to be conducted in appropriate settings. The Company may reimburse the third party providers, suppliers, vendors, subcontractors or Healthcare Providers for reasonable travel, meal and accommodation expenses, subject to applicable law and local standards. If not permitted by law, regulations, trade association rules, or contractual requirements, Company may not sponsor the attendance of a specific individual or entities to any third-party training, conferences, and similar education events.
Payments to third party providers, suppliers, vendors, subcontractors or Healthcare Providers to conduct training and education events and reimbursement of travel expenses must be in writing in accordance with Section B. The Company may not pay an honorarium fee to any third party providers, suppliers, vendors, subcontractors or Healthcare Provider for simply attending an education event or training.

    E. USE OF THIRD PARTY PROVIDERS, SUPPLIERS, VENDORS, AND SUBCONTRACTORS
If the Company uses the services of a third party providers, suppliers, vendors, and subcontractors to provide services required by the Company, the Company shall require the third party providers, suppliers, vendors, and subcontractors to undergone the process of due diligence and must follow the principles established in this Code of Conduct.

    F. SERVICE AGREEMENTS
The Company may compensate third party providers, suppliers, vendors, subcontractors and individuals, including Healthcare Providers, for bona fide consulting or service arrangement, where the services have value to the Company, and the fees are reasonable and reflect the fair market value of the services actually provided. All such arrangements must be in writing. The Company must maintain records of services and payments, including the description of work, dates of the services provided, the hours worked (if hourly) and proof of performance, such as a detailed invoice.

    G. GIFTS
The Company employees are generally prohibited from giving gifts to third party providers, suppliers, vendors, subcontractors and individuals, including Healthcare Providers. The Company may occasionally provide items that have a genuine educational function or benefit patients, such as textbooks or anatomical models, if they are modest in value and in accordance with the national and local laws, regulations and industry and professional codes of conduct of the country where the third party providers, suppliers, vendors, subcontractors and individuals, including Healthcare Providers is located. The Company may provide small tokens/gifts where appropriate under a strong local custom and not prohibited by local law or applicable industry codes, for specific occasions. Any such tokens/gifts must be the most modest token/gift suitable for the occasion, to ensure it is not, and will not be perceived by others to be, a potential means of corrupt influence. No gifts of cash or cash equivalents may be made. It is never appropriate to give items such as cash or cash equivalents, or valuable personal items (e.g. clothing, perfume, expensive alcohol, iPods, iPads, iPhones, tickets, etc.).
The description, amount and purpose of any such items given to third party providers, suppliers, vendors, subcontractors and individuals, and/or Healthcare Providers must be documented.

    H. ENTERTAINMENT
It is not appropriate to pay for entertainment of third party providers, suppliers, vendors, subcontractors and individuals, including Healthcare Providers. Vacation trips, wine tasting, night clubs, and any kind of expensive or lavish entertainment are not allowed. However, modest business courtesies are allowed where permitted by local rules and industry codes.
(i.) Business Courtesy. Where allowed by local law and industry codes, Company may provide a modest and occasional meal to third party providers, suppliers, vendors, subcontractors and individuals, including Healthcare Providers as business courtesy in the context of a business meeting so long as the primary purpose is a legitimate business reason, not a purely social interaction; the meal is incidental to the business interaction; it is provided in a setting that is conducive to bona fide scientific, educational, or business discussions; and the Company representative personally attends the meeting.
(ii.) Modest Lodging. Company may pay for third party providers, suppliers, vendors, subcontractors and individuals, including Healthcare Providers lodging for a training event or other appropriate business occasion where the lodging is modest, appropriate and reasonable based upon program requirements, convenience of attendees, and reasonable cost. The Company will not pay any additional costs associated with any trip or hotel extensions requested by third party providers, suppliers, vendors, subcontractors and individuals, including Healthcare Providers beyond the needs of the event.
(iii.) No Subsidy of Spouses, Partners or Guests. The Company may not provide meals, other hospitality, travel, lodging or other expenses for guests such as third party providers, suppliers, vendors, subcontractors, individuals such as Healthcare Providers or for any other person who does not have a bona fide professional interest in the information being shared at the meeting.
“Modest” means moderate value. “Occasional” means infrequent.

    I. EDUCATIONAL AND SCIENTIFIC DONATIONS
Grants and charitable donations are permitted only if the grant or donation is intended for a charitable or other philanthropic purpose, or to support bona fide educational or research programs. Such grants or donations must not take into account the volume or value of purchases made by, or anticipated from, the grant recipients. The Company shall keep detailed records of such grants or donations.

    J. DISCOUNTS
Discounts should be market driven, based on arms-length transactions and generally be structured as upfront price reductions or paid as rebates on a product-specific basis. Discounts must be defined at or before the time of sale in a written contract between the parties and must not result in personal benefit to any third party providers, suppliers, vendors, subcontractors, individuals, Healthcare Provider or any government official.

    K. SAMPLES AND FREE PRODUCTS
The Company may provide a limited number of sample or free products to customers for evaluation purposes or as part of an appropriate discount or promotion program, in accordance with local laws and industry codes. The provision of such products should be appropriately documented in writing to the customer institution. The Company shall keep detailed records of its samples and free products provided to customers. Provision of samples or free products should not result in personal benefit to any Healthcare Provider or government official.

    L. CLINICAL STUDIES
Where contractually required, Company shall not conduct, fund, sponsor or support any type of clinical trial and/or studies activities, including registries or any other type of study, whether organized or sponsored by a Healthcare Provider in the territory or any other person or entity, except with a prior written approval from the Principal Supplier and contracted party.

    M. TENDERS
Tenders require a fair and equal bidding process. The Company must not collaborate with a tendering authority in the creation or interpretation of tender materials or documentation in a way which could compromise fairness of the process. The Company must not give gifts, donations, or anything of value to tendering authorities or related individuals with the intent to influence the tender materials, documentation, or decision. The Company must not procure or facilitate preferred knowledge of any terms of the tender which may lead to an unlawful competitive advantage. The Company shall at all times act in accordance with the local competition, tender and any other applicable law, and shall under no circumstance discuss or share any non-public detail or part of information related to the specific bid or offer they will present. This prohibition against sharing information includes, but is not limited to prices, conditions of sales, or anything that
(i) would give the other party an anti-competitive advantage over other bidders, or
(ii) could be interpreted as direct or indirect collusion to circumvent applicable tender rules and regulations.

    N. FAIR COMPETITION
Competition laws are designed to ensure that competition remains vigorous and free from collusion. Even the perception of unlawful conduct should be avoided, including discussing prices, costs, production, products and services, bidding practices, other nonpublic business matters, sales territories, Company channels or customers with a competitor; and restricting the right of a re-seller to sell or lease a product or service at or below a certain price.

    O. COOPERATION WITH CONTRACTED ENTITIES
The Company shall cooperate with contracted entities on issues regarding periodic reports (such as forecasted sales, inventory and in-market sales), audits, and compliance with contractual requirements.

    P. USE OF SUBDISTRIBUTORS
The Company shall conduct due diligence on any prospective sub-distributors and will inform contracted entities of any engagements with sub-distributors, as required by contract. The Company will ensure that sub-distributors accept and observe all compliance obligations in the same manner and standard as observed by Globo Asiatico Enterprises, Inc.

    Q. CONFIDENTIALITY
The Company will respect proprietary and confidential information of contracted third parties, patients, customers, clients and Healthcare Provider. In addition, information provided to contracted third parties, third party providers, suppliers, vendors, subcontractors and individuals, including Healthcare Providers in good faith must be treated with the same degree of confidentiality.

    R. IMPORT AND TRADE
Where contractually required, the Company will only import products with prior written authorization by the contracted party.

    S. REPORTING A CONCERN

Globo Asiatico Enterprises, Inc. email and hotline:
Email: compliance@globoasiatico.com.ph
Contact No. (02) 982-7000; Fax No. (02) 441-0282
The Company established this site to provide an independent method to raise concerns or allegations of non-compliance confidentially and, if desired, anonymously.