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wiki:policies:anti-corruption [2023/03/21 14:13]
katcow
wiki:policies:anti-corruption [2023/03/21 15:29]
katcow
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-====== Anti-Bribery and Anti-Corruption Policy ======+====== Anti-Corruption Policy ======
  
 Nested Knowledge will not tolerate bribery and corruption.  Nested Knowledge will not tolerate bribery and corruption. 
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 This policy applies to Nested Knowledge employees, sub-contractors, and business partners.  This policy applies to Nested Knowledge employees, sub-contractors, and business partners. 
  
-==== Nested Knowledge Customer Interests ====+==== Customer Personal and Financial Interests ====
  
-Nested Knowledge delivers software services to companies engaged in biomedical research, including: pharmaceutical companies, contract research organizations, academic institutions, and non-profit organizations. +Nested Knowledge delivers software services to companies engaged in biomedical research, which may include pharmaceutical companies, contract research organizations, academic institutions, and non-profit organizations. 
  
 The research conducted by our customers may influence the following:  The research conducted by our customers may influence the following: 
-  * payer reimbursement for drugs, devices, and digital therapeutics+  * payer reimbursement for drugs, devices, and other interventions.
   * regulatory approval of drugs and devices by the FDA   * regulatory approval of drugs and devices by the FDA
   * regulatory approval of drugs and devices by governing bodies outside of the United States.   * regulatory approval of drugs and devices by governing bodies outside of the United States.
   * bids awarded to contract research organizations   * bids awarded to contract research organizations
 +  * publication success in medical journals
 +  * grants awarded to research investigators
  
 ===== II. Anti-Corruption Policy ===== ===== II. Anti-Corruption Policy =====
  
-Research in the software is conducted by our customers. Nested Knowledge staff provide training to customers, such as teaching customers how to adopt our technology for their active research projects.  +**Risk of Corruption:** Nested Knowledge staff provide training to customers, such as teaching customers how to adopt our technology for their active research projects.  
-In such roles, Nested Knowledge has a duty to avoid influencing the research integrity, data, and outcomes, and to protect the confidentiality of the research projects underway.  +In such roles, Nested Knowledge staff may learn of customer research, gain access to projects, and influence the research direction.  
 + 
 +Nested Knowledge has a duty to to prevent staff from modifying data, to avoid harming the research integrity, and to protect the confidentiality of the research projects underway. We examine these risks below: 
  
  
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 ==== > Violating Confidentiality and Gathering Intelligence ==== ==== > Violating Confidentiality and Gathering Intelligence ====
  
-A Nested Knowledge staff member may maliciously obtain access to user-log data or user research projects, i.e. "nests". In doing so, the staff member could view protocols, view early research results,  download user-uploaded documents, and view membership of an organization. +A Nested Knowledge staff member may maliciously obtain access to user research projects "nests" or user log data. In doing so, the staff member could view protocols, view early research results,  download user-uploaded documents, and view membership of an organization. 
  
-All Nested Knowledge staff sign Non-Disclosure Agreements; violation of NDAs will result in disciplinary action. +All Nested Knowledge staff sign Non-Disclosure Agreements and received training on [[https://wiki.nested-knowledge.com/doku.php?id=wiki:policies:data#iii_data_classification_policy|Data Protection]] and GDPR compliance. Violation of NDAs or security policies will result in disciplinary action. 
  
 ==== > Compromising Research Integrity ==== ==== > Compromising Research Integrity ====
  
-Nested Knowledge prohibits staff from advising customers on collecting data in a misleading or biased manner, such as: +Nested Knowledge prohibits staff from advising customers on collecting data in a misleading or biased manner, such as encouraging customers to
   * manipulate the search strategy to exclude particular articles   * manipulate the search strategy to exclude particular articles
-  * obtain access to the collected data and modify values.  +  * create overly-selective exclusion criteria 
-  * encourage biased sample selection +  * recommend meta-analysis of inappropriate study types 
-  * encourage a biased selection of endpoints +  * skip the selection of certain endpoints 
- +  * compare certain therapies, leaving other comparators that would be appropriate.  
-===== Policy Enforcement and Review ===== +  * convey numerical difference as statistical difference 
- +  * select subgroups inappropriately
-These policies will be updated on an annual basis. The next update will be done by Spring 2024. Employees will be required to review the policy annually.+
  
-These policies will be distributed to all Nested Knowledge employees and contractorsStaff members found in policy violation may be subject to disciplinary action, up to and including termination.+===== IIIPolicy Enforcement and Review =====
  
-===== Revision History =====+This policy will be updated on an annual basis. This policy will be distributed to all Nested Knowledge employees and contractors, who must review the policy annually. Staff members found in policy violation may be subject to disciplinary action, up to and including termination. 
 +===== Revision History =====
  
 ^Author^Date of Revision/Review^Comments| ^Author^Date of Revision/Review^Comments|
-|K. Cowie|03/20/2023|Initial draft completed|+|K. Cowie|03/21/2023|Drafted| 
 +|K. Kallmes|03/21/2023|Approved|
  
 [[:wiki:policies|Return to Policies]] [[:wiki:policies|Return to Policies]]
  
wiki/policies/anti-corruption.txt · Last modified: 2023/09/28 17:59 by kholub