Penpol

Compliance


What is a Compliance Hotline?

The Compliance Hotline provides a way for Terumo BCT associates to report any actual or apparent violation of legal or ethical standards in an anonymous manner. The Hotline is monitored by a third party company and is available 24 hours a day, seven days per week, 365 days per year. The monitoring company will receive any online reports filed and answer any telephone calls using the local language.

The Compliance Hotline is accessible by:

  • Calling a toll free number (available in most locations around the world):

–      United States and Canada:           888-373-6012

–      Argentina:                                    0-800-555-0906

–      Belgium                                       0800-77004

–      China (Southern)                          10-800-120-1239

–      China (Northern)                           10-800-712-1239

–      India                                            000-800-100-1071 or 000-800-001-6112

–      Japan                                          00531-121520

–      United Kingdom                            0800-032-8483

 

What are Terumo BCT's Commitments to Associates Using the Hotline?

 

  • Confidentiality: issues are reported anonymously and confidentiality is maintained to the extent possible consistent with applicable laws and regulations
  • Investigation: we will investigate any issue reported
  • Non retaliation: harassment of or retaliation against the reporting associate is prohibited for all issues reported in good faith

 

We would love to hear your questions about how to comply with the SAKURA Rules, the Code of Conduct, our compliance policies and applicable industry codes of conduct. Please contact the Law Department or send an email directly to: This e-mail address is being protected from spambots. You need JavaScript enabled to view it

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We at Terumo Penpol believe in and obey both the, letter and spirit of the law. Sakura is our creed in all our professional interactions. In line with the Terumo Groups motto ''Contributing to society through Healthcare'', and Terumo BCT Code of Conduct which guides our workplace ethics, Terumo Penpol excels in its commitment to unparalleled quality in its products and service. At TPL compliance is not just style, but lifestyle. Our success has been attributed to our ability to develop and maintain the trust of our customers and their donors and patients who rely on our products, as well as our employees, shareholders and government authorities. To gain this trust Terumo Penpol upholds "Heart of Terumo" Sakura Rules and Terumo BCT Code of Conduct the core ethics of our business and our being.

Heart of Terumo

  • Contributing to society through healthcare
  • People oriented management.
  • Open management towards society.
  • Eye on the market-Customer focused, competitor alert.
  • Quality is the core, to be forever improved.
  • Safety first.
  • Team work like orchestra
  • Positive and forward looking.
  • Always on the edge.
  • Go to Gemba
  • Heart of courtesy.

 

The 'Sakura' Way

We value work ethics and emphasize that our associates adhere to the standard code of conduct termed as Sakura Rules, which is an embodiment of Honesty, Fairness, and Integrity. The work environment atTERUMO PENPOL Pvt Limited is tailored to ensure that the views and ideas of our associates are given due respect and any sort of discrimination, kept at bay.

 

Terumo BCT Code of Conduct

We uphold our Code of Conduct that:

 

  • Embody a fundamental expression of professionalism
  • Exemplify personal integrity
  • Represent policies and guidelines for relationships with associates and others
  • Are requirements for compliance and training by each associate to ensure continued success

 

Terumo Penpol maintains a Compliance Program that reflects the principles outlined in the Terumo BCT Code of Conduct and Sakura Rules

 

Terumo Penpol LIFE represents not only who we are, but what we stand for – Open Management, Enhanced Value, Safety and Reliability, Respect for Associates and Corporate Citizenship.

Firmly rooted in core values collectively termed as the 'Associate Spirit', the work culture ofTERUMO PENPOL Pvt Limited fosters an environment conducive to growth and continuous learning. People are our greatest asset, and we place as much importance in their professional development as in the research and development of our products.

Reporting Concerns

We would love to hear your questions about how to comply with the SAKURA Rules, the Code of Conduct, the Conflicts of Interest Policy, our other compliance policies and applicable industry codes of conduct. Please contact any member of the Law Department or send an email directly to: This e-mail address is being protected from spambots. You need JavaScript enabled to view it . In addition, if you have suggestions for topics for our articles, please contact a member of the Law Department.

If you have a concern about compliance, the first step is to talk to your manager. If you are not comfortable talking to him or her, there are several other options available:

  • Talk to any member of the Senior Management Team, the Compliance Officer, any member of the Law Department or your Human Resources Business Partner
  • Email the Compliance Department via This e-mail address is being protected from spambots. You need JavaScript enabled to view it
  • Access information at the Business Conduct and Compliance page on myWorkNet
  • As a reminder, Terumo BCT has a non-retaliation policy with respect to compliance reporting. In other words, we prohibit harassment of, or retaliation against, any associate or other person who reports in good faith a known or suspected violation of law or of our policies.

 

Operating with Ethics and Integrity

We understand the pressing need to ensure access to high-quality, life-saving medical technology for patents in India, in the most affordable and efficient manner possible. To advance toward this goal, we share a commitment to and fundamental belief in operating with the highest standards of ethics and integrity. We have clear standards of conduct that we expect all of our employees, distributors, agents and anyone else acting on our behalf in India to abide by. We wish to clearly and publicly restate those standards for the benefit of all of our business partners and stakeholders, and most importantly, for patients in India who are our foremost concern.

we have clear standards of conduct that we expect all of our employees, distributors, agents and anyone else acting on our behalf in India to abide by.

 

Our Standards Clearly Prohibit Influence

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Our standards include, but go beyond, complying with the laws and regulations that govern in India. They compel us to conduct our business in India in accordance with the values of honesty and integrity. They require us to strive to prevent, detect and quickly resolve any potential violations of law or company policies.

Our standards clearly prohibit us, our distributors and agents, and anyone else acting on our behalf from attempting to influence a healthcare professional, patient or customer through any improper payment or other type of inducement for using or prescribing our products. Observations or concerns about any such improper payments may be reported confidentially or anonymously to the company involved so they can be investigated and, if true, immediately stopped using the contacts provided in this brochure.

Our standards clearly prohibit attempting to influence a healthcare professional, patient or customer through any improper payment or other type of inducement.

 

 

 

Our Standards of Conduct

1. Distributors and Other Third-Party Sales and Marketing Intermediaries Who Conduct Business on Our Behalf:

Our companies use distributors and agents to help us reach the many hospitals and healthcare providers spread across India's vast territory and population. Our distributors and agents are required to comply with applicable laws, regulations and industry codes. If an activity is prohibited for us, it is prohibited to be done through our distributors and agents as well.

2. Support for Physician Training And Education:

As in all countries, physicians in India need ongoing training and education on medical technology advances. This training builds physician capacity and skills, which will result in patients getting more access to life-saving medical device therapies. Our standards allow providing medical training and educational grants within specific guidelines.

In no circumstances may we, or distributors acting on our behalf, support travel for a physician’s spouse or partner, or finance vacations for physicians before, during or after medical conferences.

3. Physician Speaking and Consulting Contracts:

Frequently, peer education is an important way for a physician to learn the safe and effective use of new medical technology. Accordingly, our companies regularly ask experienced senior physicians (particularly those who are specialists in a particular area of therapy) to provide training on advanced technologies for younger or less-experienced physicians, as well as general physicians. We normally pay the experienced physicians fee for their time spent giving such training. Our standards require us, and distributors acting on our behalf, to set forth any such arrangements in written contracts, to ensure that the amount of payment reflects fair market value for the time spent, and to document the training event , as well as to have proof of service provided by the physician.

4. Gifts:

Our standards in general prohibit gifts to physicians and other healthcare providers, by us or distributors acting on our behalf

5. Meals and Entertainment:

Our standards prohibit us, and distributors acting on our behalf, from paying for entertainment for physicians, for example cultural or sporting events. In connection with an appropriate business meeting or educational event, we may pay for reasonable business meals and related expenses, but not for spouses or guests of physicians who do not have a professional role in the meeting or event.

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