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wiki:policies:anti_bribery [2023/03/21 14:10] katcow |
wiki:policies:anti_bribery [2023/12/20 14:32] (current) katcow |
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- | ====== Anti-Bribery and Anti-Corruption | + | ====== Anti-Bribery and Ethical Misconduct |
- | + | ||
- | Nested Knowledge will not tolerate bribery and corruption. | + | |
===== I. Scope ===== | ===== I. Scope ===== | ||
- | This policy applies to Nested Knowledge employees, sub-contractors, | + | This policy applies to Nested Knowledge employees, sub-contractors, |
- | + | ||
- | ==== Nested Knowledge Customer Interests ==== | + | |
- | + | ||
- | Nested Knowledge delivers software services to companies engaged in biomedical research, including: pharmaceutical companies, contract research 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, | + | |
- | + | ||
- | ==== > Violating Confidentiality and Gathering Intelligence ==== | + | |
- | + | ||
- | A Nested Knowledge staff member may maliciously obtain access to user-log data or user research projects, i.e. " | + | |
- | + | ||
- | 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: | + | ===== II. Anti-Bribery Policy ===== |
- | * 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 | + | |
+ | === Risk of receiving bribes: === | ||
- | ===== III. Anti-Bribery Policy ===== | + | Health Care Professionals (HCPs) may benefit financially from research demonstrating favorable outcomes for drugs, devices, or other interventions, |
- | Health Care Professionals (HCPs) | + | Government officials |
- | Government officials may have stakes in the results | + | === Risk of offering bribery: === |
- | Additionally, | + | Additionally, |
- | ===== IV. Reporting and investigating ethical misconduct ===== | + | === Code of Conduct |
- | 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 are prohibited from offering or accepting bribes. Receiving or offering bribes will result in termination, |
- | <WRAP center round info 70%> | + | ===== III. Ethical Misconduct Policy ===== |
- | Report ethical misconduct in the anonymous[[https:// | + | |
- | </ | + | |
+ | 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, | ||
- | ===== V. Policy Enforcement and Review ===== | + | <WRAP center round info 70%> Report ethical misconduct in the anonymous[[https:// |
- | 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. | + | ===== Policy Enforcement and Review ===== |
- | These policies | + | This policy will be updated on an annual basis. This policy |
- | ===== . Revision History ===== | + | ===== Revision History ===== |
^Author^Date of Revision/ | ^Author^Date of Revision/ | ||
- | |K. Cowie|03/20/2023|Initial draft completed| | + | |K. Cowie|03/21/2023|Drafted| |
+ | |K. Kallmes|03/ | ||
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