Business Code of Conduct

1. Purpose

This code sets out how Veltrion works. It is written to be usable rather than decorative, and it is the standard against which our own conduct, and that of our delivery partners, is measured.

2. We do not overstate what we are

The strongest commercial temptation in this sector is to claim more capability, more coverage and more track record than can be evidenced. We hold the following lines:

• We do not publish counts of sites, partners, facilities or "network" as a proxy for capability.
• We do not present intended, proposed or pipeline work as delivered work.
• We do not describe ourselves as holding a licence, registration or authorisation that is in fact held by a partner, or that is pending.
• We do not claim regulated capabilities we do not hold, including any suggestion of legal practice, trust or escrow facilities.
• Where a correction is needed, we make it ourselves, in writing, before anyone else finds it.

3. Regulatory statements are sourced or marked

Pathway availability, authority fees and review timelines change. Where a position is not publicly verifiable, we say so and treat verification as part of the work. We do not present an estimate as a fact, and we do not guess at a regulatory requirement in order to appear knowledgeable.

4. Client work

• Scope and fee are confirmed in writing before work begins.
• We tell a client when the answer is that they should not proceed, including when that costs us the mandate.
• We do not accept a mandate we lack the capacity or competence to deliver, and we do not compensate for that by adding scope.
• Deliverables are written to be circulated internally by the client, with sources and confidence marked.

5. Confidentiality

Client material is confidential. Delivery partners are engaged under written confidentiality terms before any client material reaches them. We do not use a client's name, portfolio or engagement as a public reference without written consent.

6. Conflicts

Competing mandates in the same product class and market are screened at scoping and declined where a conflict cannot be managed. See Conflicts of Interest.

7. People and partners

• We treat personnel, partners, counterparties and authority staff with professional courtesy.
• We do not tolerate discrimination, harassment or retaliation.
• We pay delivery partners on the terms agreed, in full, and on time.
• We expect partners to meet the standards in this code, and we say so in writing when engaging them.

8. Lawful conduct

We comply with applicable law in every market in which we work, including anti-corruption, data protection, competition, sanctions and export control requirements. Where local practice conflicts with this code, this code governs.

9. Raising a concern

Anyone, including a client, partner or member of the public, may raise a concern about conduct under this code. See Speak Up and Protected Disclosures.

Contact

Questions about this document should be directed to info@veltrionlaboratories.com, marked for the attention of the Information Officer.