I. Purpose
Envision Pharma Group (“EPG” or “the Company”) is committed to maintaining core principles of good business practices, upholding standards for ethical professional and personal conduct, and creating open channels of communication to promote a positive work environment.
This Whistleblower (Speak-Up) Policy augments our other efforts to foster a culture of integrity and ethical decision-making and provides our employees – our most important asset – with a confidential way to raise concerns. Such concerns might include discrimination, harassment, bribery and corruption, fraud, breaches of confidentiality, financial irregularities, safety issues, misconduct, unethical behavior, potential violations of law, Company policy, or any activity that could cause reputational harm to EPG.
II. Complaint reporting
When an employee observes some behavior that might raise a concern, we expect the employee to report it. EPG would rather an employee report a situation that turns out to be harmless than let possible unethical behavior go unchecked. An employee’s report can minimize the potential negative impact on EPG and our people.
Employees are encouraged to report any concerns to their direct supervisor, head of their department, or Human Resources/Legal teams. We recognize that there may be circumstances when an employee is uncomfortable reporting the issue in this way. In those circumstances, employees may also submit a complaint anonymously through EPG’s online Compliance Helpline Portal: https://envisionpharma.ethicspoint.com.
III. Confidentiality
All reports will be handled confidentially to the extent permitted by local law. Information will only be shared as needed with those involved in the assessment, investigation, and resolution of the complaint. An anonymous report through the Compliance Helpline Portal will not generate or maintain any internal connection log with IP addresses, so no information linking an employee’s work or home computer will be recorded.
IV. Non-retaliation
EPG strictly prohibits retaliation against employees who make good-faith reports. Any form of retaliation will not be tolerated and violates EPG’s code of ethics, business conduct, and this Speak-Up Policy. Violations will result in disciplinary action as appropriate, regardless of seniority.
V. Investigation
The Company takes all reports seriously and will investigate and follow up appropriately.
VI. Resolution
Following an investigation, the Company will consider and take appropriate action based on the findings to address matters raised in the complaint, which may include potential disciplinary action or other corrective measures.
Effective Date: January 1, 2024