1. Purpose
This document explains how to raise a concern about wrongdoing connected to Veltrion, and what
protection you have when you do. It is open to personnel, directors, delivery partners, clients,
authority staff and members of the public.
2. What to raise
- Bribery, corruption, or a request for an improper payment.
- Fraud, theft, or falsification of records.
- Falsification or misrepresentation in a regulatory submission, or the withholding of safety information.
- A breach of the Business Code of Conduct, including overstated capability or track record.
- An undisclosed conflict of interest.
- A risk to health or safety.
- A data breach, or misuse of personal information.
- Any attempt to conceal any of the above.
A concern about the safety of a medicine should be raised through
Adverse Event and Product Complaint Reporting as well, so that it
enters the safety reporting system without delay. Use both routes. Do not choose between them.
3. How to raise a concern
Send it to info@veltrionlaboratories.com, marked
"SPEAK UP", for the attention of the director.
Where the concern involves the director personally, or you would prefer an external route, you may
report directly to the relevant authority, or to a legal adviser of your choice. You do not need our
permission to do so, and you do not need to raise it internally first.
4. Anonymous reports
You may report anonymously. We will act on an anonymous report as far as we are able, but be aware
that anonymity may limit our ability to investigate or to protect you. Giving your name gives you more
protection, not less.
5. Protection
South African law protects certain disclosures under the Protected Disclosures Act 26 of 2000.
Beyond that statutory protection:
No person will suffer any adverse consequence for raising a concern in good
faith, including where the concern turns out to be mistaken. Retaliation against a person who
raises a concern is itself a breach of the Code of Conduct and will be treated as such. This applies to
delivery partners as well as personnel, and includes termination, non-payment or withdrawal of work.
6. What we do with it
- Acknowledge receipt promptly, where a contact route exists.
- Assess the concern and decide the appropriate form of investigation.
- Investigate proportionately, keeping your identity confidential as far as possible and lawful.
- Take corrective action, which may include terminating a partner, correcting a document, self-reporting to an authority, or notifying a client.
- Tell you the outcome, so far as we lawfully can.
7. Bad faith
A report made knowingly falsely, or for personal advantage, is not protected and may itself be a
disciplinary or contractual matter. An honest concern that turns out to be wrong is not a bad-faith
report, and will never be treated as one.
Questions about this document should be directed to
info@veltrionlaboratories.com,
marked for the attention of the Information Officer.