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Code of Conduct and Ethics—Commitment to Integrity and Ethics Commitment to Accountability and Compliance Commitment to the Work Environment Commitment to Company Information, Resources and Financial Disclosure Commitment to Governments and the Law Acknowledgment of Receipt of “The Code of Conduct and Ethics”
Commitment to Accountability and Compliance Living our Commitment The purpose of the Code is to set forth our commitment to high ethical business standards. This Codewas written to guide and reinforce prompt and consistent actions in the maintenance of those standards. Each individual must apply the standards in both letter and spirit. Where the letter of the Code is not specifica, the spirit must prevail. The Code embodies principles to which all individuals that work for or represent the company, are expected to adhere and advocate. Those individuals include:
All these individuals to the best of their knowledge and ability have an obligation to adhere to, to comply with and advocate the principles set out in this Code. Acologix will not sanction any activity that violates this Code, other applicable Company policies, or any applicable laws, rules or regulations. All individuals covered by the Code will be accountable for making good decisions and for the outcomes those decisions produce. The Code of Conductand Ethics will provide a framework and resource to help us make the right legal and ethical decision. Finally, it is the Company’s intention that the Code be the Company’s written code of ethics under Section 406 of the Sarbanes-Oxley Act of 2002 complying with the standards set forth in Securities and Exchange Commission Regulation S-K Item 406. Management Commitment All Board of Directors and officers are committed to living up to our high standards of ethical behavior. They are committed to act with honesty and integrity, avoid actual or apparent conflict between personal and private interests and the interests of the Company, including refraining from receiving improper personal benefits as result of holding a particular position with the Company. The Company’s management is also committed to develop in employees a sense of commitment to the spirit, as well as the letter, of the Code. To oversee the Company’s ethics and compliance efforts, the Company has designated the Chief Executive Officer as the Chief Compliance Officer. Employee Commitment By working for Acologix employees are agreeing to uphold the Code of Conduct and Ethics. They are also agreeing to demonstrate a personal commitment to the standards set forth in this Code. We expect our employees to do what is right and ask four basic questions before acting:
Our corporate values of integrity and ethics means employees are to live up to the standards. Employees are also expected to remember these guidelines:
By following the letter and spirit of this Code, we can help ensure that working for Acologix is a source of great pride. Corporate Governance and Internal Control Effective corporate governance begins with a strong Board of Directors, able to make independent decisions on behalf of all stockholders. Acologix will take all appropriate steps to support such a Board. The Board shall promptly determine, or designate appropriate persons (including, if so determined by the Board, the Audit Committee or the Governance Committee) to promptly determine appropriate actions to be taken in the event of violations of the Code by any director, officer, employee or other agents or representatives of the Company. In determining what actions are appropriate in a particular case, the Board (or its designee) shall take into account relevant information including the nature and severity of the violation, whether the violation appears to have been intentional or inadvertent, whether the individual in question had been advised prior to the violation as to the proper course of action, and whether or not the director, officer, employee, other agent or representative in question had committed other violations in the past. If the Board, the Audit Committee, or the Governance Committee believes that it is necessary or appropriate to amend or modify this Code to achieve its objectives or to meet requirements of any regulatory authority (including any securities exchange or market) having jurisdiction over the Company, the Board shall adopt, or the Audit Committee or the Governance Committee shall recommend to the Board for adoption of appropriate changes to this Code or other Company policies. Accountability Decisions are made every day at all levels of the organization to move forward and accomplish our business goals. Therefore, each individual is accountable for making good decisions and for the outcome of those decisions. The Code provides guidance for those decisions. Every employee at Acologix, no matter what their level within the organization is, must act as a leader by taking responsibility for everything they do and abide by the Code. Acologix does not sanction any activity that violates this Code, other applicable Company policies, or any applicable laws, rules or regulations. It is each employee’s responsibility to know and understand how to apply this Code, all other applicable policies and laws, rules and regulations in the course of conducting their activities related to Acologix. In addition, managers are responsible for compliance within the group they manage, and executive managers are accountable for compliance within their functional area. Each of us is separately responsible for our actions and conduct that violates the law or this Code and our actions cannot be justified by claiming that it was ordered by a manager or someone in higher management. Those who fail to follow the Code, policies, and the law put themselves, their co-workers and Acologix at risk. They are also subject to disciplinary action, up to and including termination of employment and prosecution under the law. Conversely, you will not be adversely affected if you refuse to carry out a directive which, in fact, violates the law or this Code. Waivers Waivers may be granted only as permitted by law and in extraordinary circumstances. Any waiver of the Code of Ethics may be made only by the Company’s Board of Directors (the “Board”) in writing. At such time as the Company is subject to the reporting requirements of the Securities Exchange Act of 1934 as amended or Japanese Security regulations if any, any waiver of the Code for any director or executive office of the Company must be disclosed on Form 8-K or similar type of report within five days, or such shorter period as may be required under applicable regulation after the Company starts public filings. Reporting Non-Compliance If you have any knowledge of a violation of our Code, you have an obligation to immediately report it to your manager, the Company’s Chief Executive Officer, Chief Executive Officer or any member of the Audit Committee of the Board (the “Audit Committee”), or the Governance and Nominating Committee of the Board (the “Governance Committee”). The point of reporting violations or suspected violations is not to get someone in trouble but to protect customers, co-workers and the Company from harm. As an additional resource for our employees to seek guidance, advice or discuss workplace behavior and ethics Acologix has partnered with Lighthouse, a leading hotline provider. If you have a concern about a questionable accounting or auditing matter, questionable behavior, or a violation of this Code, and wish to submit the concern confidentially or anonymously, you may contact the Lighthouse Hotline. You can reach the Lighthouse in many ways:
The Lighthouse will forward your concern to the chair person of the Audit Committee if the reported matter is related to an accounting or auditing matter, consistent with the Sarbanes-Oxley Act of 2002. The Lighthouse will forward all other matters to the chair person of the Governance Committee. The chair person of the Governance Committee may redirect a violation matter to the Company’s Chief Executive Officer, Chief Executive Officer, Human Resources or any member of the Audit Committee, or an outside legal counsel if appropriate. If you are aware of any ethical issue or irregularity, don’t attempt to handle an investigation on your own. Ask for help from your manager, an officer of the Company, the chair of the Audit or Governance Committee, Human Resources or the Lighthouse. Who you talk to isn’t as important as you talking with somebody. Internal Investigations Acologix may investigate behavior that might harm the Company’s reputation; that harm the safety or security of its employees or its assets; or that may violate the law, the Code, our internal policies, methods and procedures. During an investigation, Acologix will respect legal rights. All employees are required to cooperate in an investigation. In addition, the following conduct is strictly prohibited:
No Retaliation Acologix will handle inquiries discretely and use reasonable efforts to maintain, within the limits allowed by law, the confidentiality of anyone requesting guidance or reporting questionable behavior or other matters of concern under the Code. We will stand behind our Code of Conduct and Ethics and stand behind those who raise issues in good faith. No reprisals, retaliatory action or other adverse action may be taken against you for reporting a violation of this Code or a questionable accounting or auditing matter because such action may constitute a violation of federal and state law, as well as a violation of this Code and Acologix’ employment policies. At Will The Code does not alter the “at will” employment at Acologix. Nor does the Code alter the terms and conditions of your employment. Rather, it helps you know what is expected of you so that you can always act with integrity and make ethical business decisions. Related Guidelines The rest of the Code contains general guidelines for conducting the business of the Company consistent with the highest standards of business ethics and should be read together with the Acologix Employee Handbook and additional internal policies addressing particular functional areas. Together all of these documents will help employees make business decisions that will ensure that our reputation for doing business in an ethical manner never waivers. Top Close Window
Commitment to the Work Environment What we Aim For Acologix is committed to fostering a workplace that is safe and professional and that promote teamwork, diversity and trust. We also have a strong commitment to ensure that our values: ethics and integrity, commitment, respect, curious and creative learning, critical objectivity and inspiration are instilled through out the company. Dignity, Respect and Fairness The foundation of our reputation depends on the dignity, respect and fairness brought to the job by each person associated with Acologix. Unyielding personal integrity is the foundation of corporate integrity. We expect each employee to value and respect the unique character and contribution of their co-workers and to promote a positive and professional workplace for all. Equal Employment Opportunity and Diversity Our Company’s employment decisions will be based on reasons related to our business, such as job performance, individual skills and talents and other business-related factors. We will adherence to all national, state or other local employment laws and will not tolerate illegal discrimination of any time. Promoting diversity within our workforce is important. Diversity of people and ideas will provide the Company with a business advantage and will allow us to compete more successfully in today’s world. Harassment-Free Work Environment Having a professional work environment also means that our company will not tolerate any form of harassment. Harassment can be verbal, physical or visual behavior where the purpose or effect is to create an offensive, hostile or intimidating environment. Sexual harassment, in particular, can include unwelcome physical contact, sexual advances or requests for sexual favors or repeated and unwelcome sexual suggestions. Other prohibited conduct includes: offensive racial, ethnic, religious, age-related, or sexual jokes, comments or insults; distributing or displaying offensive photos, cartoons, or jokes; and using voicemail, e-mail or other electronic devices to transmit derogatory or discriminatory information. This type of behavior has no place in the company or at any company sponsored function. Likewise outside vendors, consultants and other providers of goods or services must comply with our harassment free environment when working on behalf of Acologix. Health, Safety and Security of Employees We are committed to providing our employees with a safe and secure work environment. Employees are responsible for knowing and observing all of the safety and health rules that apply to their jobs. Acologix will comply with all health and safety laws, as well as our own health and safety policies that go beyond what the laws requires. Having safety rules is not enough, though. Our companies’ commitment to safety means each of us needs to be alert to safety risks as we go about our jobs. We are all responsible for taking precautions to protect ourselves and our fellow employees from an accident, injury or unsafe condition. Additionally, each of us must promptly report unsafe or unhealthy conditions and take steps to correct those conditions immediately. A safe and secure work environment also means a workplace free from violence. Threats (whether implicit or explicit), intimidation, bullying, physical contact and violence have no place at Acologix and will not be tolerated. Weapons even if used for sporting purposes are not allowed in the workplace. Substance Abuse The safety of our employees depends on a workplace free from the effects of substance abuse. The misuse of drugs or alcohol negatively affects productivity, attendance and on-the-job safety. We expect our employees to commit not to:
Employee Confidentiality and Privacy Acologix respects the confidentiality of our employee’s personal information. This means that access to personnel records are limited to persons who have appropriate authorization and a clear business need for that information. Employees who have access to personal information must adhere to the highest standard of confidentiality regarding their use of such personal information. An employee should never provide personal employee information to anyone outside of the Company without proper authorization. Acologix provides health care benefits to its employees under a group health plan. As a result of the Health Insurance Portability and Accountability Act of 1996 (HIPAA), employees have certain rights and the Company has certain obligations regarding their individual health information. Individual health information that is contained in a designated file maintained by the Acologix is the physical property of Acologix. Such information shall only be used and disclosed in accordance with the federal regulations concerning the privacy of health information (the “Privacy Rule”). Acologix’ commitment to employee confidentiality is not a license to engage in inappropriate personal activities at work. Acologix has the right, subject to applicable legal restrictions, to monitor access and review all communications, records and information created at work or with company resources. This may include such things as business records, desks, voicemail, e-mail, intranet and internet activity, and telephone conversations.
Commitment to Company Information, Resources and Financial Disclosure What we Aim For Acologix expects our employees to share a commitment to create stockholder value by protecting our assets, managing the business in the best interest of our investors and working hard to achieve superior financial results. In pursuing this commitment, each employee is expected to act with honesty and integrity in the performance of their duties. All our employees will be held accountable to produce honest and accurate reports and records, protect company assets and resources, and to keep confidential our proprietary information. Fraud of any kind with respect to business information or company resources will not be tolerated. Protecting and Proper Use of Company Assets Each employee is entrusted with Company assets and honoring that trust is a basic responsibility to each other and our Company. All employees are responsible to use good judgment so that their company’s assets are not misused or wasted. Company’s assets are intended to help employees achieve business goals. Careless, inefficient or illegal use of company’s property has a direct impact on our profitability. This includes our time when compensated by the Company. To be successful, all employees must make the best use of their time and that of their co-workers. All employees at Acologix are expected to fulfill their job responsibilities and devote the time necessary to their work while pursing their individual work-life goals. Hours worked must be reported truthfully and accurately. Protecting Our Good Name One person at a time and one action at a time are needed from each employee to protect our name and reputation. Part of protecting our name is each of our commitment to live up to the standards found in this Code of Conduct and Ethics. Each employee must be careful to use our corporate name, any brand name or trademark owned or associated with Acologix or any letterhead stationery only for Company business and never in connection with personal activities or personal communication. Protecting Our Financial Integrity and Public Reporting Our creditability depends on the integrity of our books, records and public disclosures being valid, accurate and complete with the information supporting the entries to our books of account. Our accounting records are also relied upon to produce reports for our management, stockholders and creditors, as well as for governmental agencies. In meeting this commitment, Acologix is required by securities laws to report in accordance with generally accepted accounting principles and to maintain corporate and business records that accurately and honestly reflect all transactions. Our obligation includes more than financial information. Every employee must help ensure that reporting any business information is accurate, complete and timely. This requires, among other things, accurately recording time sheets, expense reports, regulatory data, clinical records and other essential company information. The expected commitment from all employees is that:
Purchasing Practices All purchasing decisions will be based on the best value realized by our Company and in alignment with our business standards and goals. Important components of purchasing include competitive bids, partnering arrangements, incentive-based contracts, quality verification, confirming the legal and financial condition of the supplier, and avoiding personal conflicts such as dealing with family members or friends. Agreements should be written and set forth expectations for all parties. Confidential Information Protecting confidential information our most valuable asset, is the responsibility of every person covered by this Code. In the course of work, employees may have access to confidential information or sensitive, private information regarding Acologix, its research, technology, nonpublic ideas, business strategies and plans, detailed financial data, personnel records, clinical information, employee and vendor lists and other non-public business information. Employees must commit to take seriously their responsibility to protect and not reveal or divulge any information that would be of use to our competitors or harmful to the Company if made public. Access to confidential information should be on a valid, business “need-to-know” basis. All employees will be asked to sign an “At-Will Employment, Confidential Information, Invention Assignment and Arbitration Agreement” and promise not to divulge Acologix proprietary material outside of Acologix, and that the ideas, inventions, products and processes they develop while working at Acologix are the Company’s property. An employee needs to obtain appropriate authorization and see that a written non-disclosure agreement is signed if a person outside of Acologix has a business “need-to-know” basis for confidential information. As a practical matter, discussions of confidential information in public places, like elevators, airports, restaurants and any “quasi-public” area within Acologix, such as lobby or lunchroom, should be avoided. Materials that contain confidential information, such as memos, notebooks, computer disks and laptop computers should be stored securely. Employees should not leave written material in public places, fax to a location where it could be intercepted or posted on the Internet. Unauthorized posting or discussing any information concerning the business or research on the Internet is prohibited. Also, employees may not discuss the Company’s business, information or prospects in any “chat room,” or web log (“blog”), regardless of whether you use your own name or pseudonym. Email transmissions sent outside of our intranet raise confidentiality concerns that may not be present with other forms of communication. There is a legitimate concern about the security of external email, whether it is encrypted or not. When transmitting confidential information externally by email, be certain that email addresses correspond to the intended recipients and, for particular sensitive information, employ pass-codes and other protections. Responsibility to preserve confidential information continues even after an employee‘s employment with the Company ends. Insider Information Stocks and other securities are publicly traded and their market prices are based on public knowledge of our Company. Investors could gain an unfair advantage through material inside, non-public information that might affect their decisions to buy or sell securities. Trading on, or “tipping” others about material non-public information about the Company or the companies we do business with could result in serious civil and criminal penalties for individuals and the Company. Examples of some of the information that employees should not disclosure includes financial forecasts or results, clinical information, contracts, business development plans, planned securities offerings, a change in the senior management or auditor, proposed acquisitions or divestitures, and strategic plans or information about significant changes or developments at Acologix. Retention of Records Employees are expected to follow the record retention and destruction policies that we implement and communicate from time to time. It is our Company’s policy not to destroy or alter our records or documents (whether in paper form, emails, or otherwise) in response to or in anticipation of any legal proceeding or government inquiry or investigation. Computer Use and Network Security Computer technology - hardware, software, networks and the information that runs on them is critical to our business success. Every individual at Acologix who uses a computer plays a role so that these resources operate as they should. This means employees must commit to:
Acologix expects all individuals to use good judgment when using a computer, but these simple rules can guide: Never:
Always:
Your electronic communications at work are not necessarily private. Records of your electronic communications may be made and used for a variety of reasons and, subject to applicable law, may be reviewed and monitored to verify that company policies on computer use are being followed. Keep this in mind and exercise care when you use electronic mail. Investor Relations and the Media Acologix has a designated, trained spokesperson who is the only one authorized to communicate with the media and the investment community on behalf of Acologix. Any contact with the media and the investment community should be directed to our Chief Executive Officer. Conflict of Interest and Corporate Opportunities We respect the rights of our employees to manage their personal affairs and investments and do not wish to impinge on their person lives. At the same time, we expect all of our employees to avoid allowing their private interest to interfere, or appear to interfere, with the interest of our Company as a whole. Employees are expected to make or participate in business decisions and actions in the course of their employment with us based on the best interest of our Company as a whole, and not based on personal relationships or benefits. Our employees are expected to apply sound judgment to avoid conflicts of interest that could negatively affect our Company, whether or not we have specific rules for that particular situation. Generally, our employees must avoid investments in other companies with which our Company does business if these investments could create the fact or appearance of a conflict of interest. Investing in relatively small positions of publicly traded securities of other companies is generally not prohibited so long as there is no violation of our Company policy relating to trading while in possession of material nonpublic information about other companies. Employees must obtain prior approval from the Chief Executive Officer before accepting any board of directors, trustee or committee positions of any entity (for-profit or not-for-profit) whose interests reasonably could be expected to conflict with those of Acologix. The approval of any such position may be revisited by Acologix at any time to determine whether service in such a position is still appropriate. Employees may not compete with us during the term of their employment, and may not initiate steps to compete with us while still employed by our Company. Also, while employed by us, our employees must not work for or seek or accept personal payments from any customer, supplier, competitor or other business partner of our Company, except as approved in writing by an authorized officer of our Company. Trade secrets and other non public know-how and information learned at Acologix must not be used in activities outside the Company or in other ways that could harm our business. The commitment we expect from our employees is that they will evaluate the potential conflict of interest by considering the following factors, among others:
Employees are expected to disclose to us any situation that reasonably could be expected to give rise to an actual or potential conflict of interest. Gifts and Entertainment Business gifts and entertainment can build goodwill, but they can also make it harder to be objective about the person providing them. In short, gifts and entertainment can create their own conflicts of interest. Gifts and Entertainment means anything of value, including discounts, loans, cash, favorable terms on any product or service, services prizes, transportation, vacation facilities, tickets, and gift certificates. The potential list is endless – these are just example. Some gifts and entertainment are small enough that they do not require approval like occasional meals with a business associate, ordinary sports, theatre and other cultural events, other reasonable and customary gifts and entertainment. As long as they combined market value in this category, from one source, is less that $250 in a calendar year. Accepting promotional items of nominal value, such as pens, calendars, and coffee mugs which are given to customers in general, does not require approval. Other types of gifts and entertainment are simply wrong, either in fact or in appearance, so that they are never permissible, and no one can approve these. Employees may never:
For anything that is not listed above, it may or may not be permissible to proceed. You should always think about what other employees will think about your actions and what kind of example you are setting. Likewise, you should always feel free to decline a gift and return it with a thank you note. If it is an inappropriate gift, inform your supervisor and discuss the next steps.
Commitment to Governments and the Law What we Aim For Acologix strives to be honest and fair in all our business dealings. We will compete for business aggressively but do so fairly, complying with all laws protecting competition and the integrity of the marketplace. Fair Dealings Acologix strives to outperform competitors fairly and honestly. Advantages over our competition are to be obtained through superior performance, never through unethical or illegal business practices. Acquiring proprietary information from others through improper means, possessing trade secret information that was obtained without the owner’s consent or inducing disclosure of confidential information from past or present employees of other companies will be prohibited, even if motivated by the best intentions to advance the interests of Acologix. Employees are asked to consult their supervisor or the Chief Executive Officer if they obtained information by mistake that may constitute a trade secret or other confidential information of another business, or if they have any questions about the legality of proposed information gathering. Competition and Antitrust Laws Acologix strictly adheres to what are called “competition” laws in many countries and “antitrust” laws in the United States – laws that protect markets around the world from anticompetitive behavior. These laws are based on the premise that the public interest is best served by vigorous competition and will suffer from illegal agreements or collusion among competitors. Antitrust laws generally prohibit:
Certain kinds of information, such as pricing, production and inventory, should not be exchanged with competitors, regardless of how innocent or casual the exchange may be and regardless of the setting, whether business or social. Antitrust laws impose sever penalties for certain types of violations, including criminal penalties and potential fines and damages. Understanding the requirement of antitrust and unfair competition laws of the various jurisdictions where Acologix does business can be difficult, so employees are urged to seek guidance from their supervisor or the Chief Executive Officer. International Business Laws Our employees are expected to comply with the applicable laws in all countries to which they travel, in which they operate and where we otherwise do business, including laws prohibiting bribery, corruption or the conduct of business with specific individuals, companies or countries. We also expect out employees to comply with U.S. laws, rules and regulations governing the conduct of business by its citizens and corporations outside the United States. Those laws include: Foreign Corrupt Practices Act – which prohibits directly or indirectly giving anything of value to a government official to obtain or retain business or favorable treatment, and requires the maintenance of accurate books of accounts with all company transaction being properly reported. U.S. Embargoes – which restrict or, in some cases, prohibit companies, their subsidiaries and their employees from doing business with certain other countries identified on a list that changes periodically (including, for example, Angola (partial), Burma (partial), Cuba, Iran, Libya, North Korea, Sudan and Syria) or specific companies or individuals. Export Controls – which restrict travel to designated countries or prohibit or restrict the export of goods, services and technology to designated countries, denied persons or denied entities from the U.S., or the re-export of U.S. goods from the country of original destination to such designated countries, denied companies or denied entities. Antiboycott Compliance – which prohibits U.S. companies from taking any action that has the effect of furthering or supporting a restrictive trade practice or boycott that is fostered or imposed by a foreign country against a country friendly to the U.S. or against any U.S. person. Employees are encouraged to ask questions as to whether an activity is restricted or prohibited and should seek assistance before taking any action, including giving any verbal assurances that might be regulated by international laws. Domestic Laws Acologix expects employee to comply with all laws, rules and regulations of the United States as well as any state, county, city, and any other jurisdiction applicable to the Company or its business. These include: laws covering bribery and kickbacks, patents, copyrights, trademarks and trade secrets, information privacy, insider trading, illegal political contributions, antitrust prohibitions, environmental hazards, employment discrimination or harassment, occupational health and safety, software laws, false or misleading financial information or misuse of corporate assets. Environment Compliance Acologix expects full and complete compliance with all applicable environmental laws and regulations. As a company, we are also committed to reducing the environmental impact of our activities and promoting the sustainability of the natural resources on which we depend, while providing quality products that meet the needs of our patients. Employees are expected to be committed to:
Political Activities Many governments have laws prohibiting or regulating corporate contributions to political parties, campaigns or candidates, and violators are subject to very serious penalties – including imprisonment in the care of individuals. Employees may not make any direct or indirect political contributions or expenditure on behalf of Acologix. Any proposed corporate contribution must be submitted in writing and approved by the Chief Executive Officer. Lobbying requires disclosure, is subject to specific rules and covers many kinds of activities. Employees may engage in lobbying if their work involves:
Employees must discuss these activities with the Chief Executive Officer to determine whether disclosure and other rules apply. Acologix respect the right of each of our employees to participate in the political process and to engage in political activities. While involved in their personal civic and political affairs, however, employees must at all times make clear that their views and actions are their own, and not those of the Company. Employees may not use Company resources to support their choice of political parties, causes or candidates. Government Inquiries or Investigations The business activities of Acologix are regulated and this means from time to time our employees may come into contact with Government officials responsible for enforcing the law. Acologix is committed to deal honestly with Government officials. The expected commitment from our employees is that:
What we Aim For Acologix strives to provide a decision-making process that supports employees in their search for always doing the right things for the right reason. Training and Acknowledgment Our Code of Conduct and Ethics makes clear, adherence to the law and highest standards of ethics and integrity is critical to Acologix. Our success depends on the commitment to the Code from every individual who works for or represents the Company. No single document can list and explain every question or business practice but the words found throughout the Code like respect, dignity and honesty if remembered by you will be the values that form the foundation for good decisions. Compliance does not just happen. It requires a commitment by every one of us. That is why Acologix will provide training on the Code to those who receive the document. At the end of the training we will ask each person to confirm their individual commitment to act responsibility on behalf of Acologix by:
Hotline If after you have raised a concern with the contacts suggested in this Code and have not been satisfied or are unsure about where to go, uncomfortable about using one of the other resourced identified in the Code, or wish to raise an issue anonymously, call the LIGHTHOUSE Toll Free Hotline. The contact information is listed below.
Employment-related concerns should continue to be reported through your normal channels such as your supervisor or other management. Internal Contacts If you wish to obtain advice or information about the Code of Conduct and Ethics you can talk to the Chief Executive Officer or Human Resources. Information Subject to legal constraints the complainant will receive information about the outcome of any investigation.
All of the following corporate policies and Standard Operating Procedures are reference in The Code of Conduct and Ethics. The full text of these documents is located in the Quality Assurance Department unless otherwise noted.
Acknowledgment of Receipt of “The Code of Conduct and Ethics” The Code of Conduct and Ethics represents a commitment to doing what is right. After you have read the Code please confirm your individual commitment by initialing each statement.
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