Policy & Code of Conduct

  • Business Ethics and Code of Conduct For Field Colleagues

    We conduct our operations with honesty, integrity and openness. We shall similarly respect the legitimate interests of those with whom we have relationships.We strive for continuous improvement in our performance, measuring results carefully, and ensuring that integrity and respect for people are never compromised.We are deeply committed to meeting the needs of our customers, and we constantly focus on customer satisfaction

    We are dedicated to providing opportunities for leadership at all levels in our organization.

    We play an active role in making community a better place to live and work, knowing that its ongoing vitality has a direct impact on the long-term health of our business.

    We are aware that to be a successful company, we must work together, frequently transcending organizational and geographic boundaries to meet the changing needs of our customers.

    We are committed to pursuing sound operations and performance goals while maintaining integrity in all that we do. We will operate in the best interests of the Company, and exercise care in the use of our assets and resources.

    Confidential and Proprietary Information

    The products, services, ideas, concepts and other information we produce on a daily basis are important proprietary assets for our Company, including marketing plans, sales data, clinical and medical data, customer and employee records, manufacturing techniques, pricing information and information about business development opportunities.

    Various laws enable us to protect these assets. It is important that Samarth protect and prevent inappropriate or unauthorized access to or disclosure of this information, as well as third party information provided to Samarth.

    Help protect confidential and proprietary information by following these principles:

    • Be careful when using electronic means of storing and sending information.
    • Do not disclose information to third parties, including business partners and vendors, without appropriate authorization and any required confidentiality agreements. If in doubt, check with your manager and the CFO.
    • Do not discuss confidential information in public places where others may overhear.
    • Beware of informal telephone or email requests from outsiders seeking information (commonly known as “phishing”).


    Conflicts of Interest

    A conflict of interest arises when you place your personal, social, financial or political interests before the interests of the Company. Even the appearance of a conflict can damage your reputation or that of the Company. However, many potential conflicts of interest can be resolved in a simple and mutually acceptable way.

    While your company respects your right to manage your investments and does not wish to interfere with your personal life, you are responsible for avoiding situations that present—or create the appearance of—a conflict between your interests and those of the Company.

    Any potential conflict of interest must be disclosed to and approved by your manager. Further, such approval be shared with Head-Human Resources.

    The following are examples of potential conflicts of interest.

    Personal Investments or Transactions

    Conflicts of interest may arise if you or a family member:

    • Has a substantial financial interest in a Samarth supplier, competitor or customer;
    • Has an interest in a transaction in which it is known that Samarth is, or may be, interested;
    • Takes advantage of Samarth’s corporate opportunities for personal profit; or
    • Receives fees, commissions, services or other compensation from a Samarth supplier, competitor or customer.


    Outside Business and Other Interests

    A conflict of interest exists if your outside business or other interests can affect your objectivity, motivation or performance as a Samarth employee. Your Company prohibits in your engaging or acting as a “Stockist” for company’s products during your employment.

    A second job or affiliation with a Samarth competitor is not allowed. Any pecuniary relationship with a Samarth customer, supplier or provider of goods or services is discouraged, but may be allowed with proper approval. Even when such relationship is allowed, employees are still bound by all confidentiality agreements with Samarth and all Samarth policies and procedures relating to confidential or inside information.

    Our Market Environment

    We will compete lawfully and ethically in the marketplace. We will act responsibly in our relationships with healthcare professionals, patients, consumers, hospitals, academics, governments, regulatory entities, business partners, customers, suppliers and vendors. We will provide innovative products to our customers, and we will be honest and fair in all our business dealings.

    We will:

    • Comply with all healthcare laws and regulatory requirements;
    • Inform healthcare professionals, consumers safety information for our products;
    • Market products and interact with healthcare professionals honestly in accordance with laws and regulations;
    • Monitor the safety, performance and quality of our products;
    • Interact ethically and in good faith with regulators and business partners;
    • Gather business intelligence properly.
    • Follow all SOPs that apply to our business and our role. By following SOPs, we will ensure our compliance with all laws and regulations relating to the conduct of our business.

    We will not:

    • Offer or make illegal payments to government officials or business partners, directly or through intermediaries; or
    • Offer or accept inappropriate items of value, including gifts or entertainment.


    Promotional Activities and Interactions with Healthcare Professionals

    Strict regulations govern not only our promotional activities but also our educational and commercial relationships with healthcare professionals, including our interactions with physicians, nurses, pharmacists and others who administer, prescribe, purchase or recommend prescription medications. All interactions with healthcare professionals must be guided by applicable:

    • Laws, regulations, and other industry standards;
    • National and regional industry association codes;
    • Company policies and procedures.

    Marketing Integrity

    We are committed to fair competition as a matter of corporate conduct. We abide by all laws that apply to our marketing activities. Under these laws, it is illegal to use unfair methods of competition or unfair or deceptive acts or practices in commerce, such as:

    • False or misleading promotion, or any other form of misrepresentation made in connection with sales;
    • Bribery of competitors’ or customers’ employees or of healthcare professionals; and
    • Unfair comments about competitors’ products.

    Employees in sales, marketing, medical and regulatory functions must be familiar with company policies and procedures on labelling, promotional programs, product sampling, and medical positioning of the products.

    Monitoring the Safety, Performance and Quality of Our Products

    Our field employees are responsible in ensuring reporting of adverse events, quality complaints, since we have a legal obligation to track and report product quality complaints to regulatory authorities and which may lead to product recall. Further, healthcare professionals require quick feedback from the company on all product complaints.

    Anti-Bribery and Anti-Corruption

    Your company prohibits its employees or anyone acting on your company’s behalf from offering, giving, soliciting, accepting or receiving a bribe.

    Core Value - Integrity

    “Integrity is doing right things when no one is watching”.

    Performing with integrity means setting the right priorities and delivering on our commitments while adhering to Company’s Values and SOPs. We can do this by:

    • Taking responsibility and holding each other accountable;
    • Raising concerns and asking questions;
    • Making the right decisions even when the decisions are difficult; and
    • Maintaining Samarth’s quality standards in everything we do and everywhere we operate.

    At Samarth, performance with integrity is not only what we do—it’s our DNA.

    Any violation of a law or Company policy can result in disciplinary action, including termination of employment, particularly if you:

    • Knowingly and intentionally violate the law or policy;
    • Direct others to violate the law or policy;
    • Fail to cooperate in a Company investigation of possible violations;
    • Retaliate against another employee for reporting a concern or a violation; or
    • Fail to effectively monitor the actions of subordinates.

    Integrity is at the core of our company’s identity and reputation, and we are all responsible for performing with integrity in everything we do. We are also responsible for raising concerns about risks to the company—ideally, before these risks become actual problems.

    If you reasonably believe that an employee has violated or may violate a law or company policy, you have a duty to report that information immediately to your manager, another manager, or Human Resources. Your Company believes in Open Door, anti-retaliation and confidentiality policies to protect employees.

    Retaliation against any employee who in good faith seeks advice, raises a concern or reports misconduct is strictly prohibited. Whenever you are in doubt, it is best to raise your concern.

    Non-compliance can pose serious risks for Samarth, customers, patients, and employees. By raising concerns, you give management the opportunity to address potential problems and protect the Company. For example…

    Consequences for Company:

    • Prosecution, fines and other penalties for the improper conduct of its employees
    • Disclosure to government regulator
    • Loss of business
    • Damage to Samarth’s reputation, trade and customer relations, or business opportunities


    Consequences for Patients, Customers and the Public:

    • Compromised product safety or efficacy
    • Environmental risk
    • Loss of good faith and trust in dealings with Samarth

    Our Employees

    Your company is committed to treating its employees and potential employees with fairness and respect. We believe in cooperation, teamwork and trust. Hostility and harassment are not tolerated.

    To create and maintain a safe work environment where people are treated respectfully and fairly, we will:

    • Treat employees fairly;
    • Abide by all health, safety and employment related laws and regulations;
    • Promote a positive and harassment-free work environment; and
    • Protect the health and welfare of all employees.

    We will not:

    • Engage in any form of discrimination, harassment or retaliation;


    Anti-Retaliation Policy

    Retaliation against any employee who in good faith seeks advice, raises a concern or reports misconduct is strictly prohibited. If any individual, regardless of his or her role in Samarth, retaliates against an employee who has truthfully and in good faith reported a potential violation, Samarth will take appropriate action—even if it later turns out that the employee was mistaken in reporting the matter originally.

    Discrimination or Harassment

    Samarth values a work environment that is free of verbal or physical harassment.

    This includes any unwelcome comments or actions regarding creed, religion, age, marital status, related medical condition or physical disability. This policy applies to conduct that: creates an intimidating, hostile or offensive working environment; or unreasonably interferes with an individual’s work performance.

    Reporting Discrimination or Harassment

    Employees who engage in acts of harassment or discrimination are subject to corrective action that may include termination of employment. Managers are responsible for maintaining business units that are free of harassment and discrimination. Samarth is also committed to providing an environment that is free of retaliation.

    Samarth promotes open communication throughout the Company to resolve questions, concerns, problems or complaints involving discrimination or harassment. If you experience or are aware of any discrimination or harassment, you can:

    • Talk to your immediate superior or Head- Human Resources.
    1. Taking advances in personal capacity from super stockists / stockist with an intention to cheat the super stockists / stockist
    2. Taking / borrowing company products from super stockists without specific approval from the company, and with an intention the defraud the super stockists/ stockists
    3. Fraudulently placing order with the stockist as if they are from institutions / corporate Hospitals / Govt Hospitals etc, to induce them to place orders with super stockists  to gain higher price discounts and share bounty with stockists at the cost of the company
    4. Altering genuine orders from customers to stockists by doubling or increasing quantities for availing higher discounts from super stockists and share bounty with stockists at the cost of the company
    5. Conniving with stockists / super stockists by raising bogus orders as if they are genuine orders for execution, resulting higher expiries and goods returns
    6. Approving higher breakages, expiries with stockists / super stockists to defraud the company
    7. Fraudulent reporting of daily field working or misappropriating company funds meant for promotional activities
    8. Ignoring or not reporting market irregularities (specially by your superiors) to senior management (CEO or Chairman) of the company