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Do they apply to me? Yes, they do. Some topics may seem more relevant to certain functions or departments than others. We should be able to discuss the contents of the LEO Code of Conduct with our colleagues and create a common understanding of how we conduct business in LEO through open dialogue — just as we address any standard work challenge. In my region, it is typical and expected for suppliers to provide their customers with gifts. Due to this tradition, I find it difficult to tell our suppliers that they should not give us these gifts.

What should I do? It is a question of integrity. If suppliers offer gifts regularly, you should politely advise these suppliers that our LEO Code of Conduct does not permit you or any other LEO employee to accept these gifts. Procurement officers should look for opportunities to notify suppliers of these standards before problems arise e. At LEO we do not provide gratuities to officials to ensure execution of official duties — we uphold our integrity. Seek the advice of your manager to determine if there are legally acceptable alternatives to secure the release of the drugs.

Can we pay the travel expenses for a physician involved in the approval process for new drugs to attend a meeting? Generally, the answer is no, but there may be situations where paying the travel expenses are allowed. If you believe the circumstances justify an exception, consult your manager as the laws and regulations governing such activities are complex and vary with a variety of factors, such as whether: LEO Code of Conduct 4. Can we give hospitals research grants or donations in return for business agreements?

We cannot enter into financial or other agreements by which we trade grants or donations for business. Can we give grants to patient organisations? We may grant money or services to patient organisations as long as the grants comply with local laws and regulations and do not unduly influence business or other decisions to be made by the patient organisation — thus ensuring our integrity.

We invite a physician to a dermatology congress. The physician will bring his spouse and pay the costs. He asks us to organise the practical issues. Can we do that? What the physician does as a private person is of no concern to us. We cannot provide services apart from those directly related to the invitation of the physician to the congress. The physician will bring his spouse, who is a dermatologist, and will pay the costs associated. He asks us toorganise the practical issues. What the physician does as a private person is of no concern to us, regardless of the profession of the spouse.

If the dermatologist spouse is an appropriate attendee at the congress, the spouse will receive a personal invitation related to his or her relation with LEO. The physician will bring his spouse, who is a urologist and pay the costs associated herewith. The answer is no. We cannot provide services outside those directly related to the invitation of the physician to the congress. When collaborating with a student, it turns out that the university has special equipment that we could use for a particular research task.

Can we ask the student or university to run some analyses without going through the usual channels? We cannot collaborate with any university without the collaboration being done under the relevant rules and regulations of that university and the LEO rules governing such relations. We may as long as: A Key Opinion Leader is hosting his year anniversary event, and my sales rep has asked me if he can bring a case of expensive wine as a present for the Key Opinion Leader.

Can he do that? If local laws and regulations permit, it may be permissible to bring a wine present as long as the value does not exceed normal gift-giving standards. A supplier has invited me together with other companies to a fancy evening event at which no business will be discussed. What do I do? We must never conduct ourselves in a way by which we can be seen as either seeking or be susceptible to improper influence from our business partners.

Therefore, as a general rule, we do not engage in purely social activities paid by our business partners. If the law allows for facility payments every now and then, do I do it? No, facility payments are never allowed in any form or shape, regardless of local customs and previous history. Christmas gifts of value. Do I accept them and what do I do with them?

We do not accept gifts of value. A long-time business partner has invited me and my spouse to a dinner followed by a speech on a relevant topic. You may go to the event alone observing that the dinner is not out of the ordinary in both value and venue, but you should not bring your spouse. As a sales rep I know that I am not supposed to promote use of our products outside the intended use.

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What if a physician starts asking questions about such off-label use? You should advise the physician that LEO does not recommend use of the product for purposes other than those specified in the product label. I meet somebody on the train who has scalp psoriasis. In most markets it is not allowed to make specific references to any products thus promoting such products. A journalist calls me to enquire about a particular subject. Do I talk to the journalist?

Unless you are authorized to do so, refer the journalist to your local communications person or the Corporate Communications department in Denmark. I am to make a presentation at a conference where press coverage is likely. How should I respond if approached by a journalist after my presentation? You can clarify for the reporter anything that was formally presented at the meeting. Questions that go beyond what was formally presented must be referred to your local communications person or the Corporate Communications department in Denmark.

Would I on an early stage communicate on a potential safety issue? If you have a solid basis for voicing your concern, there is ample ground to do so. Discuss the issue with your manager. I often attend meetings in a trade association. During these meetings several members may begin discussing pricing strategy.

You excuse yourself from the meeting immediately and ask to have this reflected in the minutes. Promptly advise your manager what you have observed. When issues like these are discussed, there is a risk that price-fixing or collusion could occur or be perceived to have occurred. Discussing prices is strictly prohibited. We have just hired an employee from a competitor. How much confidential information is he or she allowed to tell us about his or her former employer?

No confidential information. When we hire somebody from a competitor, the person is hired because of good business and market insights. Even so, we must not allow him or her to volunteer, nor should we ask for, proprietary or confidential information. In LEO we respect third party confidential information and intellectual property rights.

Can I communicate this information to others? You may not communicate such confidential information to others. If you know that the information being volunteered by your friend has been provided to him on a confidential basis, you should discontinue discussion of the subject at once. I agree with her on a joint price to share the tender market.

Can I do that? Agreeing on a joint price is against both the law and the LEO Code of Conduct, no matter who you are and where you are. Even discussing the price is strictly prohibited. If you believe the information being discussed is sensitive or confidential, you should advise the parties that they can be overheard. Every LEO employee has a responsibility to strive for that confidential and proprietary information is not disclosed in public. I was using my home computer and came across a chat room where sensitive LEO information was being discussed.

Disclosure of confidential information is strictly forbidden, as it may seriously harm our business objectives. Bring your observations to the attention of your manager. What are my responsibilities? As a LEO scientist and indeed any LEO employee, before you consider releasing any scientific result or information that is based on work conducted at LEO, you must follow the internal procedures governing scientific publication.

Since funding for our research comes solely from sales of our products, it is essential that we protect our discoveries through the patent process before they are made available to the public and our competitors. We have just hired somebody from our main competitor. He offers to give you the confidential brand plan for the competing product.

What do you do? Refuse to receive information like this. In LEO we respect third party information and intellectual property rights. If a government asks me for full financial disclosure including cost of goods for the purpose of setting a price or margin. You immediately excuse yourself from the conversation and promptly advise your manager what you have been subject to. We must never accept any kind of compromising information by which we can find ourselves involved in activities that are unlawful.

Acting on information like the one proposed is both in violation of our LEO Code of Conduct and is most likely unlawful in most markets. Is it allowed to date a direct or indirect report if it is a consensual relationship? It is unacceptable to begin or maintain an intimate relationship with one of your direct or indirect reports — someone in your reporting chain whose performance reviews, compensation, and promotions you may influence. Managing someone with whom you have an intimate relationship entails an inherent conflict of interest.

Even if you are acting impartially, your relationship will likely be perceived to inappropriately influence your judgment. Are there any guidelines to help us avoid potential conflicts of interest with physician customers who are also personal friends? Since there is a potential conflict of interest — or equally important, the appearance of a conflict — you must disclose these personal relationships to your manager. He or she will review the situation and determine what steps, if any, should be taken to manage the potential conflict. It is obviously important to use good judgment in managing your personal relationships with customers.

You should consider the following questions to determine whether your relationship with a customer could present a conflict of interest: On weekends? On holidays? Is an invitation to a dinner from a supplier considered a gift? No, it is not, provided that the dinner is conducted at a reasonable level of hospitality and circumstances. Dinner and venue should not be out of the ordinary. Is it necessary to report a minor accident?

To maintain a good and accident-free working environment we must report accidents and strive to eliminate unsafe practices and conditions. Reporting accidents is important as it helps us identify possible hazards and take corrective action before serious injuries can occur.


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We are behind schedule and under a great deal of pressure. May we modify a few manufacturing steps to speed up production? We must always go through proper channels to receive approval to modify existing manufacturing procedures. Some and indeed many steps may require validation by government regulatory agencies.

Other steps may be required to meet our own quality standards. The laws in my country do not prohibit dumping waste on-site. Can I dispose of LEO waste in this way? In many cases, our internal environmental standards require actions that exceed what laws in individual countries allow. I am a site services manager and am responsible for buying replacements for everything from light bulbs to equipment. Not necessarily. Sometimes the cost of the most environmental-beneficial option is disproportionate to the benefit. Generally, however, where the cost differential between options is insignificant and such insignificant cost will result in a real environmental benefit, the more environment-beneficial option should be selected.

LEO Code of Conduct 5. I am about to enter into a contract with a company that is not complying with our Environment, Health and Safety policies, but I need the work done. You stop the work temporarily. The company must remedy the situation and provide sufficient proof that this has been done before work can continue. We have heard a rumour that a key Contract Manufacturing Organisation supporting one of our future key products has a major problem with the authorities.

If I cancel the contract, our second-to-none launch will be delayed at least one year. It depends on the nature of the problem or perceived problem. The Contract Manufacturing Organisation should be confronted with the rumour and, if relevant, provide adequate proof that the rumour is false.

The way to approach the Contract Manufacturing Organisation should be discussed with your manager. I have a member of staff that continuously does not use the appropriate heavy lifting equipment. He has previously been warned that he should use it. The staff member must be confronted with his or her lack of use of the equipment and, if necessary, be met with a formal disciplinary action.

Occasionally customers behave towards me in a sexually provocative manner bordering sexual harassment. Our business depends on me maintaining good relations with these customers, but I am uncomfortable with their behaviour. No LEO employee should tolerate sexual harassment or any other form of workplace harassment, neither inside nor outside LEO. I am hosting a meeting, and some of the participants start by making jokes which are perceived as politically incorrect, ironic, and sarcastic by some of the other participants.

You should try to even out the discomforts and restore the good tone among the offended participants. Working in a multicultural environment will create situations where the traditions and doings of different cultures will meet and sometimes even clash. A first line manager has had discriminatory words against newly recruited employees regarding their sexual orientation. What type of action do I take? As LEO employees and leaders we must never engage in or support physical, psychological, verbal or any other form of harassment, hereunder regarding sexual orientation. The first line manager must be given either a clear warning or outright a dismissal, depending on the nature of the harassment and local laws and regulations.

Report what you have heard to your manager or, in the case of the offending manager being your own, to the manager above. A friend tells me that she has been using one of our products for a long time and suspects it to cause adverse events. Whenever you learn of adverse events, whether from friends or elsewhere, you must immediately inform the global Pharmacovigilance Organisation.

I am a sales rep, and a physician asks me regarding a potential safety issue with one of our products. What do I answer? You should not discuss the potential safety issue with the doctor, but refer the doctor to the global Pharmacovigilance Organisation. I work in a clinical research unit and have access to personal medical data that I would like to share with a colleague? As employees at LEO we have a strict obligation to treat personal medical information as confidential and to share it only with colleagues who need the data for their work and in line with the scope the data was provided for.

Being active in clinical research, we have an overall obligation to ensure that personal medical data is processed and handled carefully. We want to collaborate with a third party domiciled abroad. The collaboration will involve exchange of personal data. Are there any precautions we need to take? Any exchange of personal data within LEO or with third parties is subject to careful protection in accordance with applicable laws and our own data handling principles.

Can I build a large data bank with patient data indefinitely? You can never store data any longer than necessary. You may only use, collect, and process personal data such as personal information about individuals e. You are expected to protect and handle any collected or obtained personal data with due care, and you must comply with applicable laws and regulations.

Can I buy it? It depends mainly on how the data has been gathered. Discuss the potential purchase with your manager. Only one company in the world is capable of doing a particular animal study. There is one problem, though: How do we proceed? We tell the company that it must better and substantiate its animal ethics before we can enter into collaboration.

We put the project on temporary halt and in the meantime we look for another animal or non-animal model. How do we make sure that our Contract Research Organisations and partners protect the patients according to LEO standards? We choose only partners and collaborators that live up to the LEO standards. We are, as are our collaborators, committed to complying with relevant laws and regulations, international guidelines and standards such as Good Clinical Practice GCP , Good Laboratory Practice GLP , and ethical standards that meet international requirements. A physician has advised me that one of our competitors is providing him with a payment for each prescription he writes for their products.

Is it acceptable for me to do the same? No, this is not acceptable. Is this an acceptable practice? No, it is not. Observational programs may be used only to obtain data that will help LEO and physicians improve patient care through direct observation of product use in a clinical setting. There must be a contract with the physician and written protocols that identify the need for the data and that detail how program results will be used. Observational programs involving LEO products may not be used for the purpose of making physicians switch patients to LEO products, or maintaining patients on prescriptions of LEO products.


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  6. Neither, if they would create the appearance of doing so. I have been invited to the wedding of an important customer.

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    In my culture, it is expected that guests will bring cash gifts to the wedding. Are non-cash gifts acceptable? Cash gifts are prohibited. Other gifts, of symbolic value, may be allowed in business relations. One of my customers is a close friend, and we give each other valuable gifts during the gift-giving season. Is it all right for me to continue this practice? LEO does not discourage friendships with business partners, but we do require discretion and good judgment in such situations.

    In some situations, the gift may be appropriate: You must, however, inform your manager of the relationship. Your manager will assess the situation and determine how to manage any potential conflict of interest in a manner consistent with the conflict of interest policy.

    It may become necessary to assign the customer to another LEO employee. She would like to bring her spouse, at her own expense. Is it appropriate to have her do so? A spouse or companion may travel with the Key Opinion Leader to a conference provided that it is not at our expense and we provide no services i. Also, it is inconsistent with the purpose of the conference to allow spouses or companions to attend sessions or meetings where official business is discussed, i.

    I have just discovered that some materials in the field are non-compliant. You report your findings to your manager. Non-compliant materials may jeopardise our business and should not be found in the field. We are conducting an advisory board with our major Key Opinion Leaders. We have covered all expenses for them to attend, and we expect that they sign confidentiality agreement at the event. Three of the Key Opinion Leaders refuse to sign. What happens next? The three must be excluded from the meeting if the nature of the subjects discussed requires that a confidentiality agreement be signed.

    Ensure, prior to the meeting, that all members of the advisory board accept that they will have to sign a confidentiality agreement. We have flown a doctor to a conference. She wants to fly back home three days after the conference in order to sightsee or shop. Do we cover the return flight? Yes, we can do that permitted that the extended stay and later return flight does not incur extra costs for LEO.

    In some cases, flight tickets may even be less expensive, if, as an example, the trip passes over Saturday. Any difference in favour of the doctor cannot be paid out. In general, you should first seek to address your concerns with your immediate manager. If I have to report wrongdoings on behalf of my immediate manager, to whom do I address my concerns? Tripadvisor hotel reviews General field: Other Detailed field: This is not the Hilton Dallas.

    It is a turn of the century building built on a cliff with an annex. The view and situation are stunning beyond perfection. Maybe the arrivals should smile at the staff. Our staff were charming and delightful albeit formal, but this is France. They carried our bags, gave us multiple keys, and were delightful in every way and very good looking. Retrieved February 20, Those trends have since continued, said Bruce Western , a professor of sociology at Harvard University who co-authored the study.

    IMF agrees: Decline of union power has increased income inequality. Retrieved March 26, World Bank. No-Vacation Nation Revisited. Center for Economic and Policy Research. Retrieved September 8, In Paid Family Leave, U. Trails Most of the Globe. The Huffington Post. Retrieved 11 November The worst places in the world to be a worker.

    The Washington Post. Retrieved May 28, ; see also: October 29, The Wall Street Journal. May 7, New York Times. World Economic Outlook. International Monetary Fund. Euro Economics. University of North Carolina. United States Department of Labor. August 27, June 7, Federal Reserve Board of Governors. Global Wealth Report Credit Suisse. The New York Times. Retrieved April 28, University of California, Berkeley. Retrieved September 15, Journal of Economic Perspectives. Retrieved August 16, Was the crisis a game changer?

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    OECD , May Retrieved August 14, The Atlantic. The Economist. Institute for Policy Studies. Retrieved April 18, Capital in the Twenty-First Century. Belknap Press. ISBN X p. Louis Post-Dispatch. ISBN X pp. Income inequality today may be higher today than in any other era. The Washington Post Retrieved July 4, Manhattan Institute.

    Recession of —? Lecture at the University of Washington. What if the weak recovery is all the recovery we are going to get? The Washington Free Beacon. Ignoring dramatic changes in tax rules since creates the false impression that income inequality is rising. Volume 5: Evolving Fortunes. Barclays The wedges between productivity and median compensation growth. Economic Policy Institute. Retrieved November 11, Spring Productivity Growth: The Heritage Foundation.

    The Information Technology and Innovation Foundation. Washington, D. Congressional Research Service. Oakland, California: Insight Center for Community Economic Development. Income distribution and poverty. National Research Council and Institute of Medicine. Brookings Papers on Economic Activity. Brookings Institution.


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    The myth of the American Dream. Retrieved October 23, Retrieved January 11, Rector; Kirk A. Michael Cox and Richard Alm , The myths of rich and poor: New York: What if they never do? The Guardian. Per capita" Federal Reserve Bank of St. CBS News. Washington Post. United States Census. The Untold History of the United States. Simon and Schuster. BBC News. PBS Newshour. April 6, US Census. Adults Face Near-Poverty, Unemployment: Retrieved July 28, Hunger is a 'silent crisis' in the USA. USA Today. Retrieved May 12, BBC, 22 June Metropolitan Trends in the s".

    Retrieved October 5, Poverty Rate Stabilizes—For Some. Retrieved October 15, National Coalition for the Homeless , July Economic Inequality and Poverty: Social Science Quarterly Social Forces 77 3: Huber; S. Moller; F.

    Có thể bạn sẽ thích

    Stephens American Sociological Review 68 1: Mother Jones. Retrieved September 28, Retrieved July 26, Contemporary Sociology Vol. Health in International Perspective: The Telegraph. The Lancet Oncology 8 9: Atlas, In excellent health: Stanford, California: Hoover Institution Press, Stanford University. Hypertension 43 1: Canada vs. Berkeley Electronic Press. The Cato Institute. Proctor; Jessica C. The Weekly Standard. Health Affairs 26 5: Physicians for a National Health Program. Health Affairs.

    Tất cả các nghiên cứu

    Health Services Research 44 4: Cato Institute. Public Broadcasting Service. Real Clear Policy. Health Affairs 25 1: Cutting Costs or Care? Associated Press. The American Prospect. United States Government Printing Office. Greyhill Advisors. Part 2. Part 3. Beat the Press. The Institute of Science in Society. Federal Highway Administration. United States Department of Transportation. The Guardian London. Rutgers University.

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