Introduction
At Flen Health, we are committed to one Vision: we shape a world where wounds and skin disorders do not stop patients from living the life, they love.
As a company, we care. People are the centre of our care. We believe that, as human beings living in this world, patients suffering from wounds and skin disorders, their families and friends, their caregivers and healthcare professionals, and we, as industry, are all interconnected. Flen Health’s purpose is far-reaching. We are working to make patients with wound and skin disorders smile again, while simultaneously improving Flen Health as the workplace of choice and growing Flen Health in a sustainable manner.
Every single day, we help empowered patients with topical inflammatory and infectious disorders to feel good and get more out of life with our innovative health solutions. We endeavour to carry out our Mission in a resilient, ethical, humble, and respectful manner.
Fulfilling our Mission in today’s ever-changing world often comes with complex ethical considerations. How do we behave with each other? How do we earn long-term trust? And how can we stimulate innovation and initiative? How and when should we engage patients, their families, friends, caregivers, healthcare professionals, and staff? What are the limits of respectful innovation?
This Code of Conduct is a set of ethical guidelines to help you take the right decisions when you face challenging situations while navigating a world in flux. I encourage you to read them carefully and to give feedback when something does not feel right for you. If in a particular situation, you are unsure about what to do, please seek guidance in this Code and other resources available at Flen Health.
Thank you all for continuously supporting our extraordinary mission in a resilient, ethical, humble, and respectful manner.
Philippe Sollie,
Chief Executive Officer
Flen Health Group
We shape a world, where wounds and skin disorders do not stop patients from living the life, they love.
Every single day, we help empowered patients with topical inflammatory and infectious disorders to feel good and get more out of life with our innovative health solutions.
Purpose of the Code of Conduct
The Flen Health Code of Conduct (the “Code”) is an expression of Flen Health Vision, Mission, Core Values and Culture, as well as ethical and compliance principles that guide us in our day-to-day operations. The purpose of the Code is to help us make the right decisions, take the right actions, and promote compliance with applicable laws, regulations, and industry standards.
Flen Health has many additional resources to help you and advise you on the appropriate behaviour, including:
- Flen Health's policies and procedures
- Our managers and leaders
- Human Resources team
- Legal & Compliance team
- Quality team
- Privacy team
We invite you to use all these resources to further the purpose of this Code. At the end of this Code, we provide the contact details of the respective teams.
Guidelines on application
This Code applies to all of our leaders, managers, and staff in all locations where Flen Health affiliates operate worldwide. Each of us has a responsibility to know, understand, and comply with the Code and the policies and procedures that complement it. People managers have the added responsibility to help their team members understand how this Code applies to their work and decision-making. The leadership is responsible for ensuring overall compliance with this Code.
The Code also applies to third-party individuals and entities that act on Flen Health’s behalf when conducting business for Flen Health, and we expect our partners to adhere to the same high ethical standards when doing business with us, as well as in their own activities. Appropriate compliance provisions should be included in our contracts with such third parties and partners, and we will actively enforce them.
The Code itself is neither an employment contract nor any other type of a standalone contract.
If anything in this Code conflicts with applicable laws, regulations, or industry standards, the latter shall always prevail.
Core Values and Culture
The Flen Health Culture builds on the Core Values - joint accountability, which starts with trust, talent development, which implies curiosity, and agile entrepreneurship – that each of us supports, and we strive to conduct our business with integrity, transparency, and humility.
We are accountable entrepreneurs. Every day, we choose to rise above our circumstances and take ownership of our actions. This means that we demonstrate accountability for what we do as individuals and share accountability for the work that we do as a team or in collaboration with our partners and including supporting team efforts and adhering to the fundamental principles set forth in this Code.
Accountability is based on trust. We focus on and act to continually earn the trust of our stakeholders by working hard to live up to our Mission, maintaining transparency and direct communication channels, demonstrating integrity and ethical business conduct, and striving for the fair balance between the interests of all our stakeholders.
We promote a mindset that embraces lifelong learning because we approach our work with curiosity and passion.
Our vision is to shape a world where inflammatory and infectious disorders do not prevent patients from living the life they love. There is still so much that we do not know, so many unmet needs, and so many diseases that could be treated better.
We are convinced that it is curiosity and continuous education that allows us to develop meaningful innovations in collaboration with our partners, in medical therapies and beyond, which means innovation that removes the barriers that limit access to medical therapies.
Agility in innovation and collaboration
The modern world is fast paced. In such a world, creating value for each of our stakeholders requires agility.
We strive to maintain agility in our innovation. The patient needs to evolve and with them the needs of healthcare systems. Only by driving results with agility can we deliver real solutions to patients and healthcare professionals on time.
We believe that global health problems cannot be solved by individuals, enterprises, or governments acting alone. We are open to collaboration and strategic partnerships based on the same agile principles. Our communication channels remain short, and we maintain close contact with the actual and potential stakeholders.
Our stakeholders
Patients and healthcare professionals
Patients are at the heart of everything we do at Flen Health. We listen carefully to understand their unmet needs and channel our energy into creating and providing innovative, effective, safe, and easy-to-use skin and wound healing solutions so that patients around the world can continue enjoying the life they love.
We work together with healthcare professionals for the benefit of patients by mutually sharing knowledge to improve patient outcomes, listening to their expert opinions, and shaping our research and development objectives accordingly, designing and delivering clinical research, facilitating and supporting learning and research opportunities for healthcare professionals and ourselves. We are committed to ensuring that our collaboration never compromises the integrity of the patient-healthcare professional relationship, the patient’s choice of a healthcare professional, or the healthcare professional’s choice of therapy. This Code, further elaborated in Flen Health’s policies and procedures, is designed to guide our people and partners in meeting this commitment.
Fellow colleagues and leadership
Flen Health is proud to bring together many remarkable talents whose hard work and dedication enable us to live up to our Mission. We value your exceptional contribution and strive to create an atmosphere of trust, mutual respect, and inclusion to support your further personal and professional development and growth. In turn, we expect you to adhere to and promote Flen Health’s Core Values and Culture, at the workplace and in the relationships with our stakeholders.
Our leaders and managers act as role models by demonstrating integrity and humility, as well as grit and high standards of accountability that encourage and inspire others to adopt the same behaviours. Supported by various Flen Health’s teams, our leadership ensures that all principles and rules of conduct set forth in this Code are known, understood, and complied with throughout Flen Health by our staff, representatives, and partners.
We regularly partner with professionals and businesses across regions to advance healthcare.
In today’s rapidly changing world, collaboration and strategic partnerships are fundamental to delivering the right therapy to patients on time. Our partners include academic and non-academic researchers, scientific organisations, clinical investigators and clinical research organisations, hospitals, commercial companies active in the healthcare industry, including manufacturers and distributors, regulatory and compliance consultants, and many others. We seek to establish long-term mutually beneficial relationships with our partners based on the fundamental principles set forth in this Code. We expect all our partners to adhere to these principles and require the same level of integrity and ethical business conduct from their staff and associates engaged in providing products and services to or with Flen Health.
We appreciate the important role of regulators in protecting patients from health risks, providing an appropriate working environment for healthcare professionals, and ensuring that healthcare programmes serve public health and well-being. We are committed to working together with the regulators for the benefit of healthcare and complying with all applicable laws, regulations, and standards enforced by them.
We recognise and support the challenging mission of health insurers to facilitate access to healthcare by controlling healthcare costs while ensuring that communities can continue to benefit from financially viable and sustainable healthcare professionals and organisations. We strive to share this mission by making our products available in as many places as we can, and by charging fair prices while ensuring sensible long-term profitability of Flen Health's business.
We believe sustainability is a business imperative.
We strive to be a socially conscious corporate citizen committed to making a lasting positive impact on our society by protecting human rights, promoting fair labour practices, creating healthy and safe workplaces, ensuring diversity, non-discrimination, and equal opportunities. We strive to maintain a good work-life balance, and we engage with our local communities through volunteering, charity, and philanthropy.
We recognise that human health is inextricably linked to the state of the environment. We are committed to conducting our business in a sustainable manner, we endeavour to continuously minimise our environmental impact by ensuring responsible consumption and production and by limiting the carbon footprint of our infrastructures and activities. We comply with the environmental laws, regulations, and standards that apply to our operations.
Flen Health was founded and remains a family-owned business. The Sollie family has shaped our Mission, Vision and Core Values and they are deeply rooted in Flen Health’s Culture. We are committed to upholding these.
In growing the company, we continue to strive for sustainability and the long-term relationship with a focus on our extraordinary Mission, as it is put forward by the shareholders.
Our conduct principles
Ethical behaviour and decision-making in everything we do
Ethical behaviour and decision-making in any step we take – from scientific developments to how we promote and market our products – is fundamental to delivering on our Mission of helping people live the life they love because everything we do ultimately affects patients. Therefore, we are committed to conducting our business in accordance with the highest standards of moral and ethical behaviour and complying with all applicable laws, regulations, and industry standards. Each of us is further responsible for being aware of and complying with the local requirements that apply to our business area.
We work with our agents and partners to ensure that they know and understand Flen Health's ethical business practices, and we expect our agents and partners to conduct their own activities with the same level of integrity.
If you are in doubt about the meaning or application of the ethical standards or expectations outlined in this Code, or applicable laws, regulations, or industry standards, please reach out to the Flen Health Legal & Compliance team for further information.
Professional practices and attitude
Professional practices and attitudes are at the forefront of Flen Health’s activities.
We respect and value the relationships we build with our stakeholders – from patients to healthcare professionals, partners, regulators, health insurers, and others. These relationships are based on integrity, humility, transparency, and trust. We are open about our funding sources and prioritise clear and accurate communications about our products. We only encourage the use of Flen Health’s products based on their benefits for patients and only within their approved uses. We do not provide any improper inducement for prescribing or purchasing our products.
We expect that everyone at Flen Health as well as Flen Health’s representatives and partners conduct themselves in a professional manner towards each other, aligned with the Core Values, and contribute to a friendly and team-oriented working environment.
We are committed to developing, manufacturing, and distributing safe products, and providing services, that meet the requirements of applicable laws, regulations, and industry standards, as well as the performance requirements of our customers. We hold our partners accountable for the quality of products and services that they provide to us.
To ensure we meet this commitment, we have implemented the Flen Health Quality Management System Policy, which is described in our Quality Manual. The Quality Manual includes policies and documented processes for all areas of our business that affect our ability to deliver high-quality products and services that meet customer and regulatory requirements.
Everyone at Flen Health is expected to contribute actively to meeting Quality Policy and quality objectives by:
- asking questions and voicing concerns relating to any situation potentially affecting the quality, safety or compliance of our products, services, or our quality management system;
- cooperating in any required correction, corrective, and/or preventive action;
- taking ownership for processes the individual contributes to in daily work.
If you have questions or concerns related to any quality aspect of Flen Health business, please reach out promptly to the Flen Health Quality team at quality@flenhealth.com.
Patient safety without compromise is our priority.
We strive for continuous innovation and excellence throughout our business to respond to patient needs by developing and manufacturing high-quality products that meet all regulatory requirements and by pursuing quality, safety, and efficacy beyond compliance. We are transparent about any contraindications and possible side effects that patients may encounter using our products.
We further ensure patient safety by monitoring and promptly reporting any incidents associated with our products. Internally, we have established appropriate procedures for the timely reporting of such incidents. Where necessary, the reported incidents are communicated to the regulatory authorities in accordance with applicable laws, regulations, and internal rules.
Each of us is responsible for reporting to the Flen Health Regulatory team any incidents regarding Flen Health’s products within 24 hours of being made aware of them.
Human rights and fair labour practices
How we deliver on our Mission is as important as the effects our products have on the lives of patients.
We respect the rights and dignity of all people, and we operate in line with and beyond the Universal Declaration of Human Rights principles.
We respect, promote, and realise in good faith the fundamental principles and rights at work contained within the International Labour Organization Declaration:
- freedom of association and the effective recognition of the right to collective bargaining;
- the elimination of all forms of forced or compulsory labour;
- the effective abolition of child labour;
- the elimination of discrimination in respect of employment and occupation; and
- a safe and healthy working environment.
We recognise and respect the right of our staff to join or form associations to represent their rights or promote their interests. Even outside such associations, our leadership aims to maintain an open and direct dialogue with our staff.
We protect our people from unfair, unethical, or illegal working conditions, including any forms of slavery, servitude, forced or compulsory labour, or any unsafe working conditions. Child labour is prohibited.
Diversity and non-discrimination
We embrace diversity in all forms and at all levels. We firmly believe that individuals bringing in a variety of backgrounds, cultures, experiences, talents, perspectives, and opinions are key to the success of Flen Health Mission.
We reject harassment and discrimination, whether based on age, gender identity or expression, nationality, religious beliefs, racial or ethnic origin, mental or physical impediment, sexual orientation, political opinion or trade union affiliation, or any other characteristic. We will not accept any conduct that creates an offensive or hostile working environment.
These principles apply to how we treat our leadership and staff and to the recruitment process.
We recognise achievement and create equal opportunities for all colleagues, at all levels, based on their competencies. Our recruitment decisions, job assignments, opportunities for growth, remuneration, and retention are based on qualifications, individual performance, and living the Core Values and Culture of Flen Health.
Health, safety, and well-being
We prioritise the health, safety, and well-being of our people, including a good work-life balance.
We establish appropriate workplace safety programmes and organise health and safety training for staff and leadership. Personal protective equipment provided by Flen Health must be worn when working with hazards, and the locations are clearly marked and secured from non-authorised access. Everyone is required to report promptly any health or safety risk to their manager or the Health and Safety Representative at their office.
We also strive to create a working environment where our people feel happy and valued and have a good balance between the different aspects of their life. We are committed to reducing workplace stress by providing honest and timely feedback about professional performance. We ask for feedback about Flen Health’s performance, acting promptly and appropriately to such feedback.
If you have any question, concern, or proposal relating to any health, safety, or well-being aspect of your workplace, you may further reach out to your local Health and Safety Representative or the Flen Health Human Resources team. Health and Safety Representatives are appointed at each Flen Health office.
Personal and professional development
Personal development fosters professional growth by increasing mindfulness and confidence, building resilience, and uncovering hidden talents and skills. We are striving for and encouraging self-awareness and a growth mindset and create opportunities for formal and informal personal and professional development at Flen Health.
We promote a Speak-Up culture, at all levels internally at Flen Health and in relationships with our external stakeholders.
Our leadership is committed to maintaining an environment of trust, where people are encouraged to share their ideas and challenge the status quo, and where everyone feels safe to express their opinions and provide respectful feedback. We are convinced that such a culture is the most inclusive, empowering, and effective approach to enhancing our people's engagement and motivation.
In the Speak-Up culture, we also expect that colleagues and partners stand up to voice irregularities or bring behaviour that does not align with Flen Health’s Core Values and this Code to our attention. Any of these can be communicated to your manager, contact person at Flen Health, the Flen Health Legal & Compliance team, or Chief Executive Officer in the knowledge that your action will be viewed positively and that we will safeguard your interests. Communication may be anonymous, yet we encourage openness, as it enables us to respond efficiently and, where needed, take appropriate corrective actions promptly.
Local laws may recognise that in some circumstances it may be appropriate for concerns to be raised to an external party such as a regulator or a public prosecutor’s office. We strongly encourage you to seek advice before speaking out to anyone externally.
Corporate Social Responsibility
We strive to give back to the society throughout our business operations by improving labour practices, promoting diversity, inclusion and equality, engaging and supporting young professionals, as well as contributing to social projects and charitable causes and supporting local community groups in various ways.
We actively promote the 17 UN Sustainable Development Goals.
We are committed to sustainable innovation that includes preventing, minimising, and eliminating harmful impacts on ecosystems by ensuring responsible consumption and production and limiting the carbon footprint of our infrastructures and activities. We comply with the environmental laws, regulations, and standards that apply to our operations. We carefully select partners that adhere to the same fundamental principles.
We do not finance, directly or indirectly, any political parties, movements, associations, or organisations, or their representatives or political candidates. We also do not sponsor events with a political agenda.
If you would like to learn more about our CRS projects, please visit our website at https://www.flenhealth.com/corporate-social-responsibility
A conflict of interest is a situation that occurs when our personal interests or associations are in conflict or appear to conflict with the best interests of Flen Health. Several areas where conflicts of interests often arise are:
- conflicts involving family members;
- personal financial investments or ownership interest;
- business opportunities that opened up through your network at Flen Health;
- positions outside Flen Health, such as advisory roles or board seats at various third parties;
- gifts, hospitality, or payments provided by third parties to you or vice versa.
Conflicts of interests may impair our professional judgment or compromise our ability to perform our work objectively.
If you are in a conflict-of-interest situation, you must disclose it to your manager and follow Flen Health’s guidelines on review and approval of conflict of interest.
Please remember that as circumstances change, a situation that did not previously present a conflict of interest may create one. In each case, you must manage such situations transparently and in accordance with Flen Health’s policies and procedures.
Anti-corruption, gifts, and hospitality policy
We actively oppose corruption in both the public and private sectors.
Corruption can take many forms, including favouritism, bribery, kickbacks, facilitation payments, and other incentives that inappropriately influence professional judgment. Corruption generates a wide range of harmful effects, including in the healthcare industry, and is universally illegal.
Under no circumstances may we, or those acting on Flen Health’s behalf, offer or provide, directly or indirectly, anything of value to any person in exchange for securing an advantage for Flen Health, whether it be demonstrating required scientific or clinical results, accelerating a deal, or making a sale. Likewise, it is never permitted to provide anything of value as a reward for any past or present relationship with Flen Health.
We set limits on gifts and hospitality and in doing so we follow relevant country laws, regulations, and industry standards. However, it is your responsibility to ensure that any gift or hospitality you propose to offer to any third party outside Flen Health complies with the local requirements. If local requirements set more restrictive limits than Flen Health’s policies and procedures, you must always comply with such local requirements.
Everyone at Flen Health must actively manage relationships with our representatives and partners to ensure that this policy is strictly complied with.
If you are in doubt as to whether an action that you are considering or are observing may be contrary to this policy, or if you are looking for more information about anti-corruption, gifts, and hospitality laws and regulations in force in your country, please reach out to Flen Health Legal & Compliance team for further discussion.
Integrity in finance is the foundation of a successful stakeholder relationship.
Our accounts, financial statements, and records, as well as public filings or communications must accurately and completely reflect the substance and facts of Flen Health business and operations. All entries must be accompanied by adequate documentation of the underlying event or transaction, and such documentation must comply with applicable laws, regulations, and accounting standards. Leadership and financial staff have an additional responsibility to understand and comply with Flen Health’s policy regarding public disclosure of such information.
When we share information, whether voluntarily or in response to legal requirements, including pricing terms or transfers of value provided to healthcare professionals, our reporting obligations must follow the same principles of transparency and integrity.
Counterfeit products and trade compliance
We take steps to prevent and suppress counterfeiting, illegal circulation, and misuse of our products. We comply with applicable trade laws and regulations, including economic and trade sanctions programmes, export and import controls issued by governments, regional and international organisations.
An open and competitive market fosters innovation and protects the interests of patients and society as a whole.
We are committed to operating on the strength and value of our products, and we do not enter into agreements that have the purpose or effect of preventing, restricting, or distorting competition.
Confidential information is one of Flen Health’s most valuable assets, and we are committed to protecting it.
Confidential information is any information, in the broadest sense, that is not made publicly available by Flen Health or with the permission of Flen Health. Examples of confidential information include technical, commercial, financial, business, legal, and strategic information and data, of any nature and in any form, relating to Flen Health, our research and development projects, processes and products, as well as business relationships, including know-how, patented technologies and other intellectual property rights, management systems, sources of supply, our partners and terms of contractual relationships with them, pricing proposals and bids, sales and marketing plans and performance results, our staff, or any other information that could be useful to Flen Health’s competitors or detrimental to Flen Health if disclosed.
Each of us must be vigilant to protect Flen Health’s confidential information and prevent its unauthorised disclosure or use. These obligations may go beyond your engagement with Flen Health. Protective clauses should also be included in our contracts with third parties and partners and must be actively enforced.
We will respect the confidential information of others in the same (scrupulous) manner and will not inappropriately obtain or misuse such confidential information.
Data protection and responsible use of artificial intelligence
In the course of our business, we process various types of personal data that belong to our staff, patients, healthcare professionals, our agents, and representatives of our partners and other stakeholders. We recognise our increased responsibility to protect personal data, and take appropriate physical, technical, organisational, and contractual measures to ensure confidentiality. We educate our people on how to handle personal data in a safe and secure manner and in accordance with applicable privacy and information security laws, regulations, and Flen Health policies. We do not sell personal data nor receive personal data from sources that are not authorised to share it.
We are committed to the responsible use of artificial intelligence (AI) based on the principles of fairness, transparency, privacy, and security. We carefully consider what can be delegated to AI, and we do our best to ensure that any decisions made by AI are explainable, that bias is reduced, and that there is sufficient human control over such decisions. Any AI-assisted processing of personal data must respect privacy and data protection.
The full Flen Health Group Data Protection Policy is available for review at https://www.flenhealth.com/legal/data-protection-policy-1
If you have questions or concerns related to any privacy or personal data protection matter, or would like to exercise your data subject rights, please reach out to the Flen Health Privacy team at privacy@flenhealth.com. Data breaches must be reported to the Privacy team forthwith.
Non-compliance with this Code
While it is the responsibility of Flen Health leadership to ensure that all concerned are familiar with this Code, it is your individual responsibility to comply with it. Please be advised that any behaviour that is not in line with the requirements of the Code may lead to appropriate and proportionate disciplinary action and other measures.
Important contact points at Flen Health
At Flen Health, we keep all communication lines open, and we encourage giving and receiving feedback. This approach facilitates a fast and efficient exchange of information and knowledge.
For specific questions, the following contact points have been established:
- If you are in doubt about the meaning or application of the ethical standards or expectations outlined in this Code, including Flen Health’s anti-corruption, gifts, and hospitality policy, or applicable laws, regulations, or industry standards, please reach out to Anna Kombikova, General Counsel / Group Compliance Director, at anna.kombikova@flenhealth.com for further information.
- If you become aware of any incident regarding Flen Health’s products, please report the incident within 24 hours to the Flen Health Regulatory team at regulatory@flenhealth.com or +352-263-40-6271 or +32-3825-7063.
- If you have questions or concerns related to any quality aspect of Flen Health business, please reach out to the Flen Health Quality team at quality@flenhealth.com.
- If you have questions, concerns, or proposals relating to any health, safety, or well-being aspect of your workplace, please reach out to your local Health and Safety Representative or the Flen Health Human Resources team. Health and Safety Representatives are appointed at each Flen Health office.
- If you have questions or concerns related to any privacy or personal data protection matter, or would like to exercise your data subject rights or report a data breach, please reach out to the Flen Health Privacy team at privacy@flenhealth.com.
