Ethical Business Practices

Business Integrity

All bribery, corruption, extortion, money laundering and embezzlement are prohibited. Suppliers shall not confer benefits, offer and pay or accept bribes or other unlawful incentives (e.g. facilitation payments) or participate in other illegal inducements in business or government relationships. Nor shall any intermediate (e.g. sub-contractors, distributors, agents, advisers, consultants or any other business partners) be used to commit or support any of these activities. Suppliers shall take action against bribery, corruption, extortion, money laundering and embezzlement in all its forms.

Suppliers shall implement robust fraud prevention and reporting programs.
Suppliers are required to report to Boehringer Ingelheim all occurrences of fraud (actual or under investigation) involving Boehringer Ingelheim business, regardless of materiality.

Gifts, Meals, Entertainment

Suppliers doing business with or seeking to do business with Boehringer Ingelheim should not provide any gift, gratuities, hospitality, meal or entertainment to a Boehringer Ingelheim employee, government/regulatory official or any other business partner in any situation in which it might influence, or appear to influence, the employee’s or regulator’s decision in relation to the business partner.

In other situations, modest gifts, meals or entertainment may be offered to a Boehringer Ingelheim employee if they are not cash or cash equivalents, are consistent with customary business practice, not frequent or expensive, and do not violate any law.

Boehringer Ingelheim employees are forbidden to solicit or request, directly or indirectly, anything of value from any supplier doing business or seeking to do business with the company.

Fair Competition

Suppliers shall conduct their business consistent with fair and vigorous competition and in compliance with applicable antitrust laws. Suppliers shall employ fair business practices, including accurate and truthful advertising.

Identification of Concerns

Suppliers shall encourage all its workers and subcontractors to report concerns or illegal activities without threat of reprisal, intimidation or harassment, and shall investigate and take corrective action if needed.

Animal Welfare

Suppliers shall join Boehringer Ingelheim in embracing the “three Rs” of animal use (i. e., Reduction, Replacement and Refinement). In addition, suppliers should, whenever scientifically valid and acceptable to regulators and prior to resorting to animal studies, seek possible alternative (non-animal) methods, thereby minimizing the number of in-vivo studies performed. Moreover, suppliers shall also join Boehringer Ingelheim in embracing the “fourth R” for “Responsibility”, which requires highest standards of all who use animals within facilities or perform animal work on behalf of Boehringer Ingelheim.

Nagoya Protocol

Boehringer Ingelheim supports the goals of the United Nations Convention on Biological Diversity (UN CBD) and the Nagoya Protocol and is willing to address the aspects of biodiversity relevant to its activity in its business and supply chain. Thus Suppliers represent and warrant that any materials of plant, animal or microbial origin or traditional knowledge, which are subject to applicable laws on access and benefit sharing of genetic resources, or subject to access measures on genetic resources in accordance with the Nagoya Protocol on Access to Genetic Resources and the Fair and Equitable Sharing of Benefits Arising from their utilization to the United Nations Convention on Biological Diversity supplied to Boehringer Ingelheim, will meet the requirements of said Protocol as transcripted in the country of origin of said materials.

Conflict Minerals

Suppliers shall ensure that products supplied to Boehringer Ingelheim do not contain metals derived from minerals or their derivatives originated from conflict regions that directly or indirectly finance or benefit armed groups that commit serious human rights abuses.

Privacy and Data Protection

Suppliers shall respect individuals in a manner consistent with privacy and data protection laws. They shall at all times use personal data (e.g. from patients, employees, customers) in compliance with protection requirements.

Suppliers shall protect confidential information, including personal data, processed for or collected from Boehringer Ingelheim, and act to prevent its loss, misuse, theft, fraud, improper access, disclosure or alteration, including unauthorized communication and/or publication of information acquired from or on behalf of Boehringer Ingelheim.

Confidentiality

Suppliers shall protect confidential information of Boehringer Ingelheim. Suppliers requiring the exchange of confidential information with Boehringer Ingelheim are required to execute a confidentiality agreement with Boehringer Ingelheim in advance. Suppliers shall ensure, and be prepared to demonstrate, that they have appropriate safeguards in place to protect personal and other confidential information.

Unauthorized use, disclosure or loss of Boehringer Ingelheim confidential information must be reported immediately to the Boehringer Ingelheim Office of Ethics (see section RAISING QUESTIONS OR CONCERNS).

Accuracy of Business Records

All financial books and records must conform to generally accepted accounting principles. Records must be accurate in all material respects. Records must be legible, transparent and reflect actual transactions and payments.

Intellectual Property

Intellectual property rights shall be respected; transfer of technology and knowhow shall be done in a manner that protects intellectual property rights.

Trade Compliance

Suppliers must comply with all applicable import and export control laws, regulations and sanctions of the country where Supplier resides, the United States, and any other country where transactions are conducted, including but not limited to import, export, re-export, transfer or disclosure. This includes any kind of transaction of goods, software, technology or technical assistance, which might be subject to trade restrictions, regardless of the way of transfer. Suppliers shall cooperate with Boehringer Ingelheim regarding determination of applicable export control restrictions. In addition, Suppliers shall operate in full compliance with other applicable trade and customs laws.

Conflict of Interest

Suppliers should avoid any interaction with any Boehringer Ingelheim employee that might conflict with that employee acting in the best interests of Boehringer Ingelheim. For example, suppliers should not employ or otherwise make payments to any Boehringer Ingelheim employee, other than in accordance to the respective Boehringer Ingelheim contracts. If a supplier employee has a family relation to any Boehringer Ingelheim employee or if a supplier has any other relationship with a Boehringer Ingelheim employee that might represent a conflict of interest, the supplier should disclose this fact to Boehringer Ingelheim.

Clinical Trials

When engaged in clinical trials on behalf of Boehringer Ingelheim, all clinical trials shall be conducted in accordance with the global standards of Good Clinical Practices, applicable local regulatory requirements and follow the ethical principles. It is therefore crucial that these trials are conducted with the utmost regard to health and safety of volunteer participants while respecting the interest of science and society.

Human Biospecimens

The use of Human Biospecimens (HB) and associated data (i.e. donor related data) is crucial to the development of new drugs and diagnostic products, which enable the detection, prevention, diagnosis, intervention, treatment and cure of diseases. Boehringer Ingelheim is committed to the responsible use of HB and associated data by being compliant with applicable legal, regulatory and internal provisions of Boehringer Ingelheim’s Corporate Policy, as well as the Business Practice Acquisition and Use of Human Biospecimens. Boehringer Ingelheim will apply high ethical, legal, quality, privacy and data protection standards to all acquisition, collection, storage and analysis procedures undertaken. Suppliers are expected to comply with all applicable laws, rules and regulations on HB and are required to assure the informed consent (and assent, where appropriate) for HB have been collected.

Product Quality & Supply Chain Integrity

Suppliers involved in the supply, manufacturing, packaging, re-packaging, testing, storage and distribution of materials/ products on behalf of Boehringer Ingelheim will ensure compliance with applicable quality regulations and Good Manufacturing Practice, Good Distribution Practice and Good Laboratory Practice requirements for the markets in which the products are manufactured, registered and distributed.

Furthermore, suppliers shall ensure the integrity of their supply chain, avoiding counterfeiting and adulterations to protect patients and products (WHO; EU Falsified Medicine Directive; US Drug Quality and Security Act).

Marketing and Promotional Practices

All marketing and promotional materials and activities must conform to high ethical, medical and scientific standards, and comply with all applicable laws and regulations. When engaging healthcare professionals, patients or animal healthcare professionals, all suppliers must adhere to relevant industry standards of conduct that apply to them, including but not limited to the European Federation of Pharmaceutical Industries & Associations (EFPIA), the International Federation of Pharmaceutical Manufacturers & Associations (IFPMA) and the Pharmaceutical Research and Manufacturers of America (PhRMA).

Diversity in Business Relationships

Boehringer Ingelheim recognizes that diverse talents and perspectives are vital to achieve success, particularly in serving the needs of all of our customers. Boehringer Ingelheim seeks to obtain high quality goods, services and materials from companies that are owned and staffed by individuals who are minorities, women, veterans, disabled, and/or lesbian, gay, bisexual or transgender, or others who represent global diversity. Suppliers should do the same.

Procedures

Boehringer Ingelheim employees follow a set of guidelines when purchasing goods or services. Any business issues and/or negotiations regarding the proposed purchase are coordinated by Purchasing, with the Boehringer Ingelheim employee providing input and technical assistance as needed. It is important to note that work should only start after a purchase order or a signed contract is received by the supplier. Starting work without having a contractual agreement in place will be at the supplier’s own risk. When a purchase order has been issued, any associated invoice must include the relevant purchase order number on the invoice. There are also cases where a formal qualification is required prior to use of materials and services.

Use of Boehringer Ingelheim Name, Trademarks or Logo

Use of Boehringer Ingelheim name, trademarks or other similar information in supplier advertising, media publications or product endorsements is prohibited without the prior written approval of Boehringer Ingelheim.

Media and Public Relations

Boehringer Ingelheim has established policies and procedures for external communications. Only authorized Boehringer Ingelheim officials can issue statements to the media or general public about Boehringer Ingelheim or its products.