PPD expects that vendors that provide products and/or services to our company comply with the letter and spirit of all applicable laws, rules and regulations in the countries in which they operate, as well as the principles set out in our Vendor Code of Conduct. Translated versions of PPD’s Code of Conduct and Anti-Corruption Anti-Bribery policies are available at the following link: http://www.ppdi.com/About/Ethics.
Expect Integrity: PPD Vendor Code of Conduct
PPD is committed to ethical and lawful behavior, and to acting professionally and fairly in all business dealings and relationships. We seek to maintain high ethical standards and to comply with all applicable laws and regulations. Vendors’ activities may influence PPD’s reputation and relationship of trust with our clients and employees, and as such we expect our vendors to maintain the same high legal and ethical standards.
We expect integrity – of our employees, our directors and our vendors – in all we do. We have a code of conduct for our employees and directors that describe the policies, procedures and principles that they must follow. Likewise, this Vendor Code of Conduct (“code”) incorporates the principles of lawful and ethical conduct that PPD expects of its vendors (and any of their subcontractors, collectively, “vendors”). PPD expects its vendors to have their own code of conduct that addresses business conduct and practices and to maintain a hotline or other mechanism for vendor employees to report any allegations of misconduct on the part of the vendor or PPD.
PPD expects its vendors to comply with the letter and spirit of all applicable laws, rules and regulations in the countries in which they operate, as well as the principles set out in this code.
In addition, PPD expects its Vendors to comply with all of the principles set out in this code, which include the following:
Business and Financial Records
We expect vendors to provide honest and accurate invoices. Invoices should be itemized, quote the PO number (where relevant), be supported by appropriate documentation and comply with all other requirements as set out in the relevant contract(s). Invoices may not be split to circumvent approval requirements.
PPD takes a zero-tolerance approach to bribery and corruption, and we require our vendors to take the same approach. A vendor may not:
- Offer or allow anything of value to be given on behalf of PPD in order to gain an improper advantage
- Offer or allow anything of value to be given to a PPD employee in order to gain an improper advantage
- Ask for or accept anything of value which the vendor knows or suspects is being offered in order to obtain an improper advantage
Vendors are required to comply with PPD’s Anti-Corruption Compliance Policy (the “policy”), a copy of which is provided to all vendors.
Tax Evasion and the Facilitation of Tax Evasion
PPD takes a zero-tolerance approach to our vendors committing or facilitating tax evasion. Vendors (and each of their subcontractors) are expected to have policies and procedures in place to prevent employees and other associated persons from committing or facilitating tax evasion.
Antitrust/Fair Business Practices
Vendors must comply with antitrust laws – known globally as “competition laws.” Further, vendors must abide by fair business practices, including truthful and accurate advertising.
Gifts and Entertainment
All purchases made by PPD will be made on the basis of price, quality and service, and PPD will deal with its vendors fairly, honestly and openly. PPD employees are required to conduct all business and interactions with vendors in strict compliance with the applicable provisions of PPD’s Code of Conduct, Anti-Corruption Compliance Policy and Charitable Giving Policy.
Vendors should avoid any actions with PPD employees during any vendor selection or re-selection process that could give others the impression of favoritism or other improper advantage. Furthermore, vendors should not offer, and PPD employees must not accept, gifts or entertainment that might compromise, or appear to compromise, an employee’s judgment or independence.
Confidential Information, Privacy and Data Security
Vendors must sign and abide by PPD’s confidentiality disclosure agreements, which protect the proprietary information of PPD and its clients. Where vendors handle personally identifiable information on behalf of PPD, belonging to PPD or its clients, then the vendor must contractually commit to apply privacy and information security safeguards. Such vendors shall also be subject to an online information security assessment.
Where applicable, vendors agree to treat animals humanely, including with minimal stress and pain. Alternatives to animal testing should be used whenever possible.
Mechanism for Reporting Concerns
Vendors will maintain a system for their workers to report any concerns or illegal activities in the workplace without threat of reprisal, intimidation or harassment. If concerns are reported, vendors will investigate and take corrective action where needed.
PPD expects its vendors to treat their workers with dignity and respect, and to uphold their human rights.
Fair Treatment and Anti-discrimination
Vendors will provide a workplace free from harsh and inhumane treatment such as sexual harassment and/or corporal punishment, and free from illegal discrimination.
Wages, Benefits and Working Hours
Vendors will comply with local applicable wage laws regarding wages, overtime hours and mandated benefits. Vendors will communicate with workers about compensation, including any overtime pay, in a timely manner.
Freely Chosen Employment
No vendor will use any form of slave or forced labor; this includes involuntary prison labor.
No vendor will use child labor. All employees shall be age 18 and over unless (1) a country’s legal age for employment or age for completing compulsory education is under 18 and (2) the work is non-hazardous.
Human Rights Compliance
Vendors shall (and shall ensure that each of their subcontractors shall) comply with all applicable human rights laws, statutes, regulations and codes from time to time in force, including but not limited to the UK Modern Slavery Act 2015. Vendors shall implement due diligence procedures for their own suppliers, subcontractors and other participants in their supply chains, to ensure that there is no human rights violations, including but not limited to slavery, child labor or human trafficking in their supply chain. Vendors shall notify PPD as soon as they become aware of any breach, or potential breach, of human rights in their business or supply chain.
Freedom of Association
Vendors must respect their workers’ rights to associate together regarding working conditions, and to join unions, form work councils and engage in labor negotiations, including collective bargaining. Vendors shall not intimidate or harass any worker who participates in such associations.
Health, Safety and Respect for Environment:
PPD expects vendors to provide a healthy and safe working environment, and to be environmentally responsible to minimalize any adverse impacts of operations on the environment.
Protection of Workers
Vendors shall protect workers, and any visitors to their facilities, from exposure to chemical, biological and physical hazards. Vendors shall monitor their workplace for any other safety hazards and provide a safe and secure environment for workers and visitors. Information and training regarding any hazardous materials – including pharmaceutical compounds and pharmaceutical intermediate materials, where applicable – will be provided by vendors.
Vendors are encouraged to conserve natural resources, to reuse and recycle and to avoid use of hazardous materials where possible.
Vendors must comply with applicable environmental regulations, including having, maintaining and operating in compliance with all permits, licenses, registrations and restrictions where required.
Vendors shall have systems to ensure the safe and lawful handling, movement, storage, recycling/reuse or management of waste, air emissions and wastewater discharges.
Processes, Emergency Preparedness and Response
Vendors shall have appropriate processes in place to identify, prevent and mitigate any risk of a chemical spill or other event that would pose a threat to worker safety and/or to the environment. These processes include emergency plans in the case of an unsafe event and response procedures should such an event occur.
Vendors are expected to adopt management systems in furtherance of this code, the policy and their principals:
- Identify and comply with all applicable laws and regulations in the countries where they operate.
- Assess and manage risks in all areas address in this code and the policy.
- Maintain documentation to show confirmation with this code, the policy and relevant laws and regulations.
- Communicate the expectations of this code, the policy and provide effective training to workers.
- Ensure continual improvement in processes.
- Allocate appropriate resources to the ensure compliance with this code and the policy.
Vendors can report any suspected compliance or ethics violations related to services being provided to PPD by contacting the PPD Ethics Hotline:
- Within the U.S. and Canada: +1 888 898 4087
- For Rest of World: +1 770 613 6324
Diversity in PPD’s Supply Chain
Vendors shall engage socially and economically different categories of vendors through inclusive sourcing processes that promote equal opportunities.