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--- wiki:policies:anti-corruption [2023/03/21 14:13]
katcow
+++ wiki:policies:anti-corruption [2023/09/28 17:59] (current)
kholub
@@ Line 1: / Line 1: @@
-====== Anti-Bribery and Ethical Misconduct Policy ======
+====== Anti-Corruption Policy ======
+Nested Knowledge will not tolerate bribery and corruption.
 ===== I. Scope =====
 This policy applies to Nested Knowledge employees, sub-contractors, and business partners.
+==== Customer Personal and Financial Interests ====
+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:
+  * payer reimbursement for drugs, devices, and other interventions.
+  * 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
+  * publication success in medical journals
+  * grants awarded to research investigators
+===== II. Anti-Corruption Policy =====
+**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 staff may learn of customer research, gain access to projects, and influence the research direction.
-===== II. Anti-Bribery Policy =====
+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:
-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.
+==== Manipulating Data ====
-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.
+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.
-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.
+==== Violating Confidentiality and Gathering Intelligence ====
-=====  III. Ethical Misconduct Policy =====
+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.
-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.
+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.
-A report of misconduct, via any mode of communication, will launch an investigation into the affected individuals.
+==== Compromising Research Integrity ====
-<WRAP center round info 70%>
+Nested Knowledge prohibits staff from advising customers on collecting data in a misleading or biased manner, such as encouraging customers to:
-Report ethical misconduct in the anonymous[[https://forms.gle/A1CVQbB45iiVyk568|report form]].
-</WRAP>
+  * manipulate the search strategy to exclude particular articles
+  * create overly-selective exclusion criteria
+  * recommend a meta-analysis of inappropriate study types
+  * skip the selection of certain endpoints
+  * compare certain therapies, leaving other comparators that would be appropriate.
+  * convey numerical difference as statistical difference
+  * select subgroups inappropriately
-===== Policy Enforcement and Review =====
+===== III. Policy Enforcement and Review =====
-This policy 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 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.
+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 =====
+===== Revision History =====
 ^Author^Date of Revision/Review^Comments|
-|K. Cowie|03/21/2023|Initial draft completed|
+|K. Cowie|03/21/2023|Drafted|
+|K. Kallmes|03/21/2023|Approved|
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