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--- wiki:policies:anti_bribery [2023/03/21 14:09]
katcow
+++ wiki:policies:anti_bribery [2023/03/21 19:23]
katcow
@@ Line 1: / Line 1: @@
-====== Anti-Bribery and Anti-Corruption Policy ======
+====== Anti-Bribery and Ethical Misconduct Policy ======
-Nested Knowledge will not tolerate bribery and corruption.
 ===== I. Scope =====
@@ Line 7: / Line 5: @@
 This policy applies to Nested Knowledge employees, sub-contractors, and business partners.
-===== Nested Knowledge Customer Interests =====
+===== II. Anti-Bribery Policy =====
-Nested Knowledge delivers software services to companies engaged in biomedical research, including: pharmaceutical companies, contract research organizations, academic institutions, and non-profit organizations.
-The research conducted by our customers may influence the following:
-  * payer reimbursement for drugs, devices, and digital therapeutics.
-  * regulatory approval of drugs and devices by the FDA
-  * regulatory approval of drugs and devices by governing bodies outside of the United States.
-  * bids awarded to contract research organizations
-===== 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.
-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.
-==== > Manipulating Data ====
-If a customer explicitly grants a Nested Knowledge staff member access to their nests, there is a risk the staff may manipulate collected data for their personal or financial gain. This includes changing the value of a data points and excluding studies. Such behavior will result in instant termination, and if applicable, legal action will be initiated.
-==== > 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.
-All Nested Knowledge staff sign Non-Disclosure Agreements; violation of NDAs will result in disciplinary action.
-==== > Compromising Research Integrity ====
-Nested Knowledge prohibits staff from advising customers on collecting data in a misleading or biased manner, such as:
-  * manipulate the search strategy to exclude particular articles
-  * obtain access to the collected data and modify values.
-  * encourage a biased sample selection
-  * encourage a biased selection of endpoints
-===== III. Anti-Bribery Policy =====
+=== Risk of receiving bribes: ===
 Health Care Professionals (HCPs) may benefit financially from research demonstrating favorable outcomes for drugs, devices, or other interventions, in which the HCP has financial stakes.
 Government officials may have stakes in the results of research studies. For example, literature reviews may influence government agency funding, the commercial success of a drug entering market, and drafting of new legislation.
-Additionally, obtaining government contracts may financially benefit software companies, such as Nested Knowledge and the employees within. As such, we strictly prohibit bribery to officials and require all employees to disclose their conflicts of interests, including family members and friends in government agencies.
+===Risk of offering bribery: ===
+Additionally, obtaining government contracts may financially benefit software companies, such as Nested Knowledge and the employees within. They also may benefit from receiving authorship on publications.
-===== IV. Reporting and investigating ethical misconduct =====
+=== Code of Conduct ===
+All Nested Knowledge staff are prohibited from offering or accepting bribes. Receiving or offering bribes will result in termination, and may result in legal action. Bribes are not limited to cash offerings.
+We require executives to disclose their conflicts of interests, including family members in government agencies or healthcare organizations.
-Employees who suspect ethical misconduct may report it anonymously through a form. The reports will be receipted by at least three Nested Knowledge staff members.
+=====  III. Ethical Misconduct Policy =====
+Employees who suspect ethical misconduct may report it through an anonymous form. The reports will be received by three Nested Knowledge staff members.  A report of misconduct, via any mode of communication, will launch an investigation into the affected individuals. We retain the right to audit activity in the software, through [[https://wiki.nested-knowledge.com/doku.php?id=wiki:policies:access#iv_audit_trails_and_logging|activity logs]].  We also may investigate emails and launch a financial audit.
 <WRAP center round info 70%>
@@ Line 59: / Line 28: @@
-===== V. Policy Enforcement and Review =====
+===== Policy Enforcement and Review =====
-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.
+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.
-These policies will be distributed to all Nested Knowledge employees and contractors. 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|
-|K. Cowie|03/20/2023|Initial draft completed|
+|K. Cowie|03/21/2023|Drafted|
+|K. Kallmes|03/21/2023|Approved|
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