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Free policy template · Word

Code of Conduct for Pharma Company

A pharma code of conduct sets the ethical and compliance standards for everyone in a pharmaceutical company, from plant and laboratory staff to medical representatives and leadership. It covers GMP and data integrity, ethical interaction with healthcare professionals, adverse event reporting, confidentiality of formulations and clinical data, conflicts of interest, anti-bribery, workplace conduct and speaking up.

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[Highlighted] = fill in
[Company Logo][Company Name]

CODE OF CONDUCT

Company:
[Company Name]
Version:
[Version Number]
Effective Date:
[Date]
Approved By:
[Authorised Signatory]

1. Purpose

Patients depend on the quality and safety of our medicines. This Code sets the standards of integrity that every person working for [Company Name] must follow.

2. Scope

This Code applies to all employees, trainees, directors and, where relevant, consultants, contract staff and agents acting on the company's behalf, at plants, laboratories, offices, depots and in the field.

3. Definitions

  • Healthcare Professional (HCP): doctors, pharmacists, nurses and others who prescribe, dispense or recommend medicines.
  • Adverse Event: any undesirable medical occurrence in a person using a company product.
  • Confidential Information: formulations, processes, data, dossiers, plans and any non-public information.

4. Standards of Conduct

  1. Quality and GMP: Follow approved SOPs and GMP at all times. Never release, ship or promote a product you know or suspect to be non-compliant.
  2. Data integrity: Record data truthfully, at the time of activity, and never alter, backdate, delete or selectively report results. Do not share user IDs or passwords.
  3. Ethical promotion: Promote products only for approved indications with accurate, balanced claims. Do not offer gifts, cash, travel or any benefit to HCPs or their families to influence prescribing. Sponsorships and medical education must follow the company's approval process and applicable codes.
  4. Drug safety: Report any adverse event, special situation or product complaint you learn about to [Pharmacovigilance Contact] within one working day.
  5. Confidentiality: Protect formulations, clinical and stability data, regulatory submissions, pricing and personal data of patients and employees.
  6. Anti-bribery: Never offer or accept bribes, facilitation payments or kickbacks, including to officials, inspectors, distributors or hospital staff.
  7. Conflicts of interest: Declare any financial interest, family relationship or outside work that could conflict with your duties, including with suppliers, distributors or competitors.
  8. Respectful workplace: Treat everyone with dignity. Harassment, discrimination and retaliation are prohibited. Complaints of sexual harassment are handled by the Internal Committee under the POSH Act 2013.
  9. Safety and environment: Follow EHS rules, handle chemicals and waste responsibly and report incidents.

5. Procedure for Raising Concerns

Raise questions or concerns with your manager, HR, Quality, Compliance or through the confidential speak-up channel at [Whistle-blower Contact]. Reports made in good faith are protected from retaliation.

6. Responsibilities

Managers must lead by example and ensure training. Compliance and HR maintain this Code, run annual training and investigate concerns fairly.

7. Non-compliance

Violations will be investigated and may lead to disciplinary action, as per company policies and the applicable service rules, after a fair hearing.

8. Review

This Code is reviewed annually by Compliance and HR.

Declaration: I have read and understood this Code of Conduct and agree to comply with it.

Employee Name: [Employee Name]
Employee ID: [Employee ID]
Department: [Department]
Date: [Date]

What this template includes

  • Purpose and applicability to all staff and agents
  • Quality, GMP and data integrity commitments
  • Ethical promotion and interactions with doctors and chemists
  • Pharmacovigilance and product complaint reporting
  • Confidential information and IP protection
  • Anti-bribery, gifts and conflicts of interest
  • Respectful workplace and POSH
  • Speak-up channel and non-retaliation

When to use it

  • Setting up a compliance framework for a pharma company
  • Onboarding employees across plant, R&D and field force
  • Preparing for regulatory, customer or partner audits
  • Refreshing conduct expectations after a compliance incident

How to customise this template

  1. 1Align the promotion section with the marketing code you follow
  2. 2Insert your pharmacovigilance contact
  3. 3Set gift and hospitality limits per policy
  4. 4Add your whistle-blower channel details
  5. 5Have every employee sign the annual declaration

HR tips

  • Train field force on what counts as an inducement with real examples
  • Make data integrity a cultural value, not just an SOP
  • Protect whistle-blowers visibly
  • Review the code with each major regulatory change

This code is a starting point. Review it against applicable drug, marketing and anti-corruption laws, labour laws, your licences and with a legal adviser before adoption.

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Frequently asked questions

Why does a pharma company need a separate code of conduct?+

Pharma faces specific risks such as data integrity, unethical promotion and drug safety reporting, which generic codes do not cover in enough detail.

Can medical representatives give gifts to doctors?+

Gifts and inducements to healthcare professionals are restricted under applicable marketing codes. The company code should prohibit them except as specifically allowed.

Who must report adverse events?+

Every employee who becomes aware of an adverse event or product complaint, regardless of department, should report it to pharmacovigilance promptly.

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