At Orphan Poland sp. z o.o. ("Orphan Poland" or the "Company"), we are committed to
conducting our business with the highest ethical standards. As a company dedicated to
supporting patients with rare diseases, we value integrity, transparency, responsibility,
and care in everything we do.
This Third Party Code of Conduct (the “Code”) sets out the expectations we have of our
external partners, including suppliers, vendors, agents, subcontractors, co-promote
partners and other third parties (collectively referred to as “Third Party
Representatives”). Compliance with this Code is a condition for initiating and maintaining
business relationships with Orphan Poland.
Ogólne obowiązki
Third Party Representatives are expected to:
Operate in full compliance with applicable laws, regulations, and ethical standards
Respect privacy and confidentiality
Maintain safe, fair, and inclusive workplaces
Act with honesty and integrity in all business dealings
Support environmental sustainability and human rights
Postępowanie biznesowe i etyka
Anti-Bribery/Anti-Corruption (ABAC):
Orphan Poland maintains a zero-tolerance policy toward bribery and corruption. Third
Party Representatives must never engage in bribery, facilitation payments, or
kickbacks—whether dealing with public officials or private individuals. Compliance with
applicable anti-corruption and anti-money laundering laws, including but not limited to
the U.S. FCPA and the UK Bribery Act, is mandatory.
Antitrust and Fair Competition:
Third Party Representatives must comply with antitrust and competition laws in all
jurisdictions where they operate. Business must be conducted fairly and without unlawful
collusion or market manipulation.
Business and Financial Records:
All financial records must be accurate, complete, and maintained in compliance with
applicable laws. Invoices must reflect actual transactions, be supported by
documentation, and not be manipulated to avoid review or approval procedures.
Confidentiality:
Third Party Representatives must protect confidential and proprietary information of
Orphan Poland and not disclose it without prior written authorization.
Intellectual Property:
Respect for intellectual property rights is essential. Third Party Representatives must
protect both Orphan Poland’s IP and that of other entities (e.g., patents, trademarks,
copyrights, trade secrets).
Marketing and Promotional Practices:
All marketing and promotional materials must be truthful, evidence-based, and in
compliance with applicable laws. The use of Orphan Poland’s name, trademarks, or
product references requires prior written consent.
Data Privacy:
Third Party Representatives must comply with all applicable privacy and data protection
laws. They are required to implement adequate safeguards to protect personal
information against unauthorized access, disclosure, or misuse.
Subcontractors:
Partners must ensure that their subcontractors and supply chain also adhere to the
standards set forth in this Code. Appropriate due diligence and oversight mechanisms
must be in place.
Trade Sanctions, Export Controls, and Competition:
Third Party Representatives must comply with relevant trade laws, including EU, U.S.,
and Swiss sanctions and export control regulations. Business practices should promote
fair competition and avoid abuse of dominant positions.
Standardy jakości i zapewnienie
Orphan Poland expects all products and services provided by Third Party
Representatives to meet mutually agreed-upon quality standards and to comply with
Good Distribution Practices (GDP), relevant ISO standards, and applicable national
regulations.
Third Party Representatives must operate under a quality management system and
ensure appropriate communication with Orphan Poland regarding compliance,
deviations, and improvements.
Standardy pracy
Third Party Representatives must:
Prohibit forced labor, human trafficking, and involuntary work
Avoid child labor and only employ young workers under safe, legal conditions
Ensure fair wages, benefits, and working hours aligned with local law
Provide a workplace free of discrimination, harassment, and abuse
Respect workers' rights to association and collective bargaining
Zdrowie, bezpieczeństwo i środowisko
Worker Health and Safety:
Third Party Representatives must ensure:
Hazard information and training are provided to workers
Systems are in place to identify, assess, and control workplace risks
Proper emergency preparedness and response plans exist
Safe working environments free from chemical, biological, or physical hazards
Environmental Stewardship:
Partners must:
Comply with environmental laws and obtain necessary permits
Minimize waste, emissions, and environmental impact
Promote resource efficiency and sustainability (e.g., water, energy)
Have systems in place to prevent and mitigate environmental incidents
System zarządzania
Third Party Representatives must implement and maintain management systems to
ensure ongoing compliance with this Code, including:
Commitment of adequate resources and leadership to ethical practices
Risk assessment and internal control processes
Proper financial documentation and controls (e.g., no “off-the-books” records)
Allowing audits or assessments by Orphan Poland when reasonably requested
Training employees on ethics and compliance standards
Raportowanie zastrzeżeń
If you suspect any unethical behavior or potential violation of this Code, please report it
to: compliance@orphanpoland.pl. Reports may be made anonymously. Orphan Poland
is committed to confidentiality and non-retaliation for good faith disclosures.