Code of conduct
A Message from our CEO
At Sampled, our reputation is the cornerstone of our success. Maintaining the trust of our investors, customers, partners and employees is the foundation of our current and future growth. We maintain this trust by acting with integrity and ethics in all we do. Sampled is committed to conducting our business in accordance with the highest standards of ethical behavior and legal compliance.
Our Board of Managers has adopted this Code of Conduct (the Code), which outlines Sampled’s standards as they apply to our interactions with employees, customers, our communities, suppliers, vendors, regulatory agencies, business partners and competitors. It is critical that we exhibit fairness and integrity in every interaction and decision. The Code complements our company’s values in terms of how we do business. Together they form the foundation of our daily activities and outline our expectations for every single one of you.
Sampled is trusted and respected in the business, medical and scientific communities. It is through your continued commitment to ethical business conduct and legal compliance that we will preserve our hard-earned reputation.
This Code applies to all directors, officers, employees, and consultants of Sampled as well as any directors, officers, employees, and consultants of any affiliate. It is your responsibility to read and understand the Code and to comply with the applicable laws, rules and regulations, as well as with our Company’s policies and procedures. We rely on you to uphold our core values and conduct our business honestly, fairly and with integrity.
We encourage you to take this opportunity to review this Code and our policies, and to discuss any questions you may have with your manager or with the Compliance Department at email@example.com. If you have any questions at any time about these obligations or are in doubt about the correct course of action, do not guess what you should do; seek advice from the resources identified in this Code.
Chief Executive Officer, Sampled
You are responsible for:
- Reading and understanding this Code and all corporate policies. If you have any questions, please contact firstname.lastname@example.org.
- Acting, every day, in accordance with the Company’s expectations of you. Your actions are critical to protecting our good name.
- Speaking up! If you hear something or see anything that leads you to believe that potential noncompliance with this Code, our policies or any law has occurred, report it immediately.
We foster a collaborative, inclusive work environment to facilitate innovation and deliver excellent business results.
Equal Employment Opportunity and Non-Discrimination
Sampled is an equal opportunity employer. Sampled prohibits discrimination and harassment of any type and affords equal employment opportunities to employees and applicants without regard to race; color; religion; sex; pregnancy, a childbirth or a related medical condition; national origin; age; disability; genetic information; veteran status; an employee’s needs as a victim of domestic violence, sex offenses or stalking; or any other classification prohibited by federal, state or local laws. We respect the diversity of ideas and encourage an atmosphere of trust, fairness, openness and candor. We place a high value on a tolerant, respectful work environment.
Safe Work Environment
We provide a safe working environment because the health and safety of our employees is our number one priority. Follow all safety procedures. Do not work impaired because of alcohol or drug use. We have a zero-tolerance policy for workplace violence. Do not engage in any act that could cause another individual to feel threatened or unsafe. Take immediate action, regardless of your role, if you see a situation that could put others at risk.
Combatting Trafficking in Persons
Sampled prohibits its employees and agents from engaging in trafficking in persons; procuring commercial sex acts; using forced labor in performance of contracts; withholding or destroying employee identification or immigration documents; using fraudulent tactics in recruiting workers or using recruiters who engage in such tactics; or charging employees recruitment fees. If you become aware of any of the above activities occurring, or any credible information of such activities, contact your supervisor, the Human Resources Department, or the Legal Department immediately. If an employee or agent is found to be in noncompliance with this policy, the Company will take immediate appropriate action, up to and including termination.
Sampled prohibits the solicitation of employees and the distribution and posting of materials on or at Company property during working time. This includes electronic property and resources by any employee or non-employee, except Company-sponsored programs related to Sampled products and services.
Ethical Business Conduct
We only engage in ethical and fair business practices. Sampled is committed to ethical and compliant business practices that align to the spirit and letter of the various applicable laws, regulations and contractual requirements to which we are subject.
Compliance with Laws
Sampled employees are required to comply with laws that govern the healthcare and biotechnology industries in the United States along with a myriad of federal, state and local procurement regulations. The consequences for noncompliance with healthcare laws and public sector regulations are severe and can include criminal and civil sanctions for both Sampled and employees. Sampled’s compliance with these laws is crucial to the Company’s mission. These laws are complex and can evolve at any time based on new regulations, legislation or judicial interpretations. Employees and business partners are expected to comply with all laws including, but not limited to, the laws described below. If you have any questions about whether these laws could be implicated by a particular situation in which you or the
Company are involved, please reach out to the Legal Department or the Compliance Department.
Sampled requires you to report actual or potential noncompliance with the Code, the Company’s policies and procedures, or any applicable law. Failure to report suspected noncompliance may result in disciplinary action up to and including termination. See below to ensure you are familiar with the procedure for reporting suspected noncompliance.
Anti-Bribery and Anti-Corruption Laws
We do not bribe anyone, ever. Laws prohibiting bribery, including the US Anti-Kickback Statute, the US Foreign Corrupt Practices Act, the UK Bribery Act and various other country-specific laws, make it illegal to improperly influence or attempt to improperly influence both government and private sector decisions or actions.
The federal Anti-Kickback Statute makes it a crime to pay or receive anything of value to induce the prescribing or purchasing of items or services paid for by a federal healthcare program. As applied to Sampled, the law prohibits payments intended to induce someone to use or recommend that others use our lab or biorepository services that are reimbursable under a federal healthcare program or to reward someone for choosing or recommending that others choose to use our services. The law’s intent is to protect the independence and objectivity of healthcare-related decisions that involve federal healthcare programs and their patients. Many states have laws similar to the federal Anti-Kickback statute making it a violation to pay anything of value to influence the purchasing or prescribing of items paid for by state healthcare programs, private health plans and even individuals. To remain compliant with the federal Anti-Kickback Statute and its state equivalents, Sampled prohibits any form of improper inducement (or any conduct that may give the appearance of improper inducement) to use the Company’s services, regardless of whether a federal healthcare program is involved. Any type of payment, including, but not limited to, direct compensation, gifts and entertainment, and educational or research grants may implicate the Anti-Kickback Statute and should be thoroughly reviewed by the Legal Department in advance.
Similarly, do not offer, promise, provide, solicit or accept anything of value on the Company’s behalf or in connection with Sampled business. Do not engage in any conduct that could be considered a form of bribery, kickbacks, corruption, facilitation or “grease” payments, extortion or embezzlement. Do not hire a third party to engage in any corrupt behavior on the Company’s behalf. Put simply: bribes are illegal, unethical and prohibited by this Code. Please carefully review the upcoming Compliance with Laws Policy and the Anti-Bribery and Anti-Corruption Policy for more information about your role in fighting corruption in all our business activities.
False Claims Act
The federal civil False Claims Act and its state equivalents prohibit submitting, or helping or causing someone else to submit, a false claim for reimbursement to the federal government. The False Claims Act has been used to assert liability against labs for improper referrals of lab tests and other diagnostic services in violation of the Anti-Kickback Statute. Labs also have incurred False Claims Act liability for alleged misrepresentations with respect to services or for not refunding overpayments for services. The civil penalties and damages assessed for violations of the False Claims Act can be severe.
Making a false claim or false statement to the government, either directly or through a contractor or other agent, can subject both the Company and individual employees to civil and criminal sanctions including fines, suspension, debarment and prison sentences. It is the responsibility of each employee to ensure that all claims, statements and invoices submitted to the government are accurate, truthful and not misleading. If you have a reason to believe that a false oral or written statement has been made, you must immediately notify the Compliance Department.
Ensuring Accurate Books and Records
We ensure that Company books and records, specifically our financial accounting records, are true, accurate and complete. Follow Sampled policies around financial reporting controls as well as all applicable accounting principles. Even if you are not directly responsible for the preparation of financial reports, you are responsible for ensuring that relevant transactions – from a dinner receipt to an invoice approved for payment – accurately reflect the transaction. All records relating to the Company’s performance of government contracts shall be retained for any required statutory or regulatory period, as well as any contractually required period. Should any employee become aware of any records, material, or other information that reveals fraud related in any way to a government contract, that employee must immediately bring such records, materials or other information to the attention of the Compliance Department. Ensuring that our Company maintains true and accurate records also extends to our laboratory records in compliance with Good Manufacturing Practices (GMP) and other applicable rules and regulations.
Interactions with Healthcare Professionals
All employees must ensure that their interactions with Healthcare Professionals (HCPs) are conducted in accordance with the highest ethical standards. Requirements and limits related to HCPs are generally stricter than those of the general private sector. When interacting with healthcare professionals:
- never engage in deceptive or misleading marketing and/or sales practices
- never harass, intimidate, coerce or attempt improperly to influence a healthcare professional through any means
- never offer any form of inducement to a healthcare professional
- never pay more than fair market value for a healthcare professional’s services
- always respect requests from healthcare
- professionals to stop receiving sales-related calls and/or materials
- always provide accurate and complete information that is not misleading in any way
The Headline Test
When contemplating anything from a text message to a large financial decision, use the headline test. You must be able to answer each of these questions, “Yes!”
- Is the action legal?
- Is the action ethical?
- Does the action comply with our Company values?
- Does the action comply with this Code and our Company policies?
- Would you be OK if a story about the action turned into a headline?
If the answer to any of these questions is no, stop and talk to your manager.
Conflicts of Interest
We always act in the best interests of our Company. Your duty of loyalty lies with Sampled. Avoid situations that result in actual or perceived conflicts of interest. A conflict of interest exists or may arise when an employee’s personal, financial or other interests compromise that employee’s ability to make sound and objective decisions that are in the best interests of the Company. If you discover that a personal relationship, investment, opportunity or position could compromise – or could even appear to compromise – your duty of loyalty to Sampled or a project in the public health space, disclose it immediately to your manager. Some conflicts may be mitigated via disclosure and some basic preventative measures. The Compliance Department can help you evaluate the best choices for your unique situation. Other conflicts must always be avoided. Please carefully review the upcoming Conflicts of Interest Policy for more information about potential conflicts and how to address them.
General Guidance Regarding Conflicts of Interest
- never personally profit from a Company or customer transaction
- avoid situations where interests of family members or close relatives may be at odds with the Company
- avoid secondary employment or other activities that may negatively impact your job performance – employees are not permitted to affiliate with any Company competitors, customers, suppliers or business partners without prior written approval from the Compliance Department
- never accept gifts from anyone that Sampled is doing or considering doing business with
- never use Company property for personal gain
Take this simple test
If the answer to any of these questions is “yes,” then you have a potential Conflict of Interest:
- Could you or someone close to you financially benefit from a Sampled or customer business transaction?
- Could anyone perceive that you are engaging in favoritism as it relates to an employee, vendor or supplier due to your personal relationships?
- Could your position outside Sampled interfere with or influence any Sampled business decision?
- Could your personal or familial relationships cause anyone to question your duty of loyalty to Sampled?
- Do you have any significant financial interest that could directly and significantly affect the design, conduct or reporting of PHS-funded research?
Additional Considerations and Requirements
Because we are an institution that works with entities in the Public Health Service (PHS), additional obligations exist specific to Financial Conflicts of Interest that must be carefully managed.
Employees are prohibited from using any non-public Company or government information for personal gain and may be required to sign a non-disclosure agreement prohibiting such activities.
A personal conflict of interest in the context of government contracting may exist when an employee has a financial interest, personal activity or relationship that could impair that employee’s ability to act impartially and in the best interest of the government while performing under the government contract. This personal conflict of interest can arise especially with employees who are responsible for performing acquisition functions closely associated with inherently governmental functions.
An “organizational conflict of interest” occurs when, because of the Company’s other activities or relationships with other persons, the Company is unable or potentially unable to render impartial assistance or advice to the government, the Company’s objectivity in performing the contract work is or might be otherwise impaired, or the Company has an unfair competitive advantage. For example, an organizational conflict of interest may result when the nature of work performed by the Company on one contract (such as developing a lab test specification) creates an actual or potential conflict of interest on a future procurement or contract opportunity. It is the responsibility of each employee to recognize and report to their supervisors any activities or relationships that might create an organizational conflict of interest so the Company can take appropriate actions to avoid any such organizational conflict.
Political Contributions, Activities and Lobbying
Sampled is prohibited from using federal funds to pay persons, such as lobbyists or consultants, to influence or attempt to influence executive or legislative decision-making in connection with the award or modification of any government contract. No employee may hire such a lobbyist or consultant without the Company’s prior written authorization. Further, the Company must comply with the prohibition under applicable law on benefits to members of Congress under federal contracts.
Sampled is prohibited from making contributions of money or other resources to candidates, officeholders and political parties at the federal level. As a result, you may not act on behalf of Sampled to contribute money or resources to candidates, elected officials or political organizations or use Sampled assets to support a candidate or issue at any level of government. These restrictions apply to services and facilities, such as office space, videoconferencing technology, photocopying and administrative support. Further, you may not lobby or try to influence the actions of government officials regarding legislation or policy decisions that relate to Sampled or to the Company’s business without prior approval from the Legal and Compliance Departments.
The Company nevertheless encourages, and respects the rights of, individual employees to be involved in political activity and to contribute their own time and resources. Such activity, however, must not take place on Company time or property or involve the Company’s name. Sampled will not reimburse employees for any political contributions they may make. Laws and regulations governing contributions to state and local candidates vary from state to state, and Sampled expects all employees to act in accordance with all such laws and regulations. If you have any questions about political contributions or activities, contact the Legal Department.
Fair Competition and Fair Dealing
We deal fairly with our customers, suppliers, business partners and competitors. Sampled embraces the competitive marketplace and is committed to observing the highest standards of honorable and ethical conduct in all relationships with the Company’s competitors and to compliance with antitrust and fair competition laws. Noncompliance with these laws can lead to civil or criminal liability for both Sampled and
9 Effective Date: March 31, 2023 employees. You must ensure that your actions cannot be construed as “price-fixing” or a “restraint on trade.” In addition, the advancement of the Company’s business interests through the dissemination of unverified information or other unfair actions intended to damage competitors is prohibited, as are any other anti-competitive activities. Consult the Legal Department before considering any type of agreement or understanding that might appear to limit any party’s freedom to conduct business with others or in a particular geographic area.
Fair Competition and Fair Dealing Guidelines
- We will not mislead anyone about our products or services through our marketing or other materials
- We will not use a competitor’s trade secret or other confidential business information to our advantage
- We will not engage in unauthorized use, copying, distribution or alteration of software or other intellectual property
- We will not discuss, propose, consider or enter into any agreement or understanding with our competitors concerning prices, price policies, or terms and conditions of sale
- We will not engage in bid rigging with our competitors
- We will not agree to allocate markets or customers with our competitors
- We will not agree to boycott a supplier or customer with our competitors
The Privacy Act prohibits the disclosure of a record about an individual from a system of records absent the written consent of the individual unless the disclosure is pursuant to one of twelve statutory exceptions. The Privacy Act also provides individuals with a means by which to seek access to and amendment of their records and sets forth various agency record-keeping requirements. The Company complies with the Privacy Act when handling personal data under its government contracts.
Cooperation with Investigations and Audits
Given the highly regulated status of our business operations, it is possible that government officials, including auditors and investigators, will contact Sampled employees regarding the Company’s compliance with federal and state healthcare program requirements or the provision of goods and services to the government .
Sampled also may conduct internal audits and investigations. It is a condition of employment for all employees to cooperate fully with any Company or governmental authorities conducting an audit or investigation. Full cooperation includes providing timely and complete responses to questions and document requests.
You may learn material non-public information about the Company, or a competitor, customer, supplier or business partner in your role at Sampled. Material non-public information may include plans for mergers or acquisitions, marketing strategy, financial results or other business dealings that are not publicly available. You are prohibited from trading securities of a publicly held company or influencing others (including family members and friends) to trade securities based on material non-public information. Criminal and civil sanctions for violating securities laws and engaging in insider trading are severe. If you have a question about whether the sale or purchase of a security is permissible, contact the Legal Department.
We comply with all restrictions on imports, exports and other dealings with certain countries, persons, or groups. Employees may not support boycott activities.
We understand the value in providing gifts, meals and entertainment to create goodwill and sound working relationships. Such business courtesies should be for a legitimate business reason, reasonable and customary, infrequent, given openly and transparently, and properly recorded in our books and records. Do not give or receive gifts or entertainment that are lavish or made for the purpose of influencing a business decision. All Sampled employees and their immediate families are prohibited from accepting any cash, gifts, special accommodations, favors, or use of property or facilities from anyone with whom the employee does business or is negotiating on behalf of Sampled.
There are laws that limit business courtesies to government officials and different limits depending on the country, state and even role of the recipient. US government employees are subject to complex laws and regulations that strictly limit their ability to solicit, receive or accept gifts and gratuities, including meals, favors, entertainment, loans, hospitality or other things of value from companies and persons with whom the federal government does business or over whom it exercises regulatory authority. Employees are prohibited from offering any gift or gratuity to a US government employee or representative. If you have any questions about whether extending a gift or gratuity to a US government employee or representative is permissible, please contact the Legal Department.
When competing for government contracts and subcontracts, Sampled may be required to certify that no offer, promise or gift of any gratuity, entertainment, money or other thing of value has been or will be made to any government agency or any other employee of the US government or member of their family or household. If any such discussion, offer or promise does occur, you must immediately notify the Legal Department.
Similarly, Employees are prohibited from offering anything of value, including but not limited to coffee mugs, water bottles, notepads, ballpoint pens and other items of nominal value, to HCPs without prior review and approval by the Legal Department for compliance with state and federal Anti-Kickback Statutes and healthcare program requirements.
Please carefully review the upcoming Business Courtesies Policy to understand more about what you may and may not provide, and never provide business courtesies of any kind (other than water or coffee / tea) to an HCP without prior approval or to a Public Sector employee under any circumstances.
Use of Third Parties
We choose our partners carefully. Sampled’s reputation is tied to the actions of those with whom we choose to do business. If you engage a business partner, vendor or supplier, you must ensure that its reputation in the market is solid. Ensure they are qualified to do the work that we are hiring them to do. Only pay fair market value for the products or services they are providing the Company. Immediately escalate to your manager or the Legal Department if you suspect that one of our customers, suppliers, vendors or business partners is potentially engaging in money laundering or any corrupt behavior.
Safeguard Company Assets
We protect the Company’s assets and ensure their efficient and appropriate use.
Employees must use Sampled’s resources and property solely for the benefit of the Company. You must not misappropriate or use Company assets, whether through theft, fraud or other means, for personal benefit. Company assets are anything that is not generally available to the public and include, but are not limited to, physical resources, intellectual property, intangible assets and proprietary information, information concerning pricing, products and services being developed, and a prospective acquisition or sale. You must hold these Company assets in the strictest of confidence.
The use, expenditure and disposal of Sampled’s resources must be documented as required by Sampled’s procedures. Documents and other records must be maintained in accordance with the requirements of applicable law, contracts and Company policies and shall not be used for personal gain or benefit. No employee or anyone acting on Sampled’s behalf shall take any action to circumvent Sampled’s system of internal controls or provide misleading information in Company documents and records.
Treat Company property as if it were your own. Protect our physical assets, such as our offices, supplies, IT equipment, lab equipment and company funds. Do not steal or abuse company property. Sampled assets only may be used for business purposes unless prior approval is provided by the Legal Department. Spend the Company’s money as if it were your own. Do not waste funds on unnecessary expenses. Seek bids to obtain the best deal possible for the Company. Confirm that products or services were delivered as agreed before approving and paying invoices.
Our most valuable asset, aside from our employees, is our information. Protect the Company’s confidential information as well as the Company’s intellectual property. Mark Company confidential information as “Confidential” or “Proprietary.” Store and transfer such information securely and protect it from any unauthorized access by third parties. Keep such information strictly confidential and do not share it with anyone who is not authorized to view it. Confidential information also includes information relating to Company employees and other persons or entities that the Company is obligated by law or agreement to maintain in confidence. The Employee Handbook also addresses the use of other confidential information, and you should consult it, along with your supervisor and/or Human Resources, if you have any questions or concerns.
- never use proprietary or confidential information in any other way than is required to perform your job
- your obligation to protect proprietary or confidential information continues even after you leave the Company – all files, records and other information acquired or created in the course of your employment are the property of the Company and, like Sampled’s physical property, must be returned upon separation
- do not discuss or review confidential information in places where you can be easily overheard or observed by others
Examples of confidential company information include:
- strategy documents
- product roadmaps
- financial data
- sales projections
- marketing plans
- customer lists
- merger or acquisition activity
- research and technical data
Intellectual Property and Data Rights
Intellectual property is an expression of a new and useful concept that is legally protected and to which the originator is granted certain exclusive rights. “Data rights” is a shorthand way to refer to a party’s licensing rights in technical data and computer software. The extent of these rights depends on the source and level of funding. It is essential for all employees to safeguard the Company’s trade secrets and confidential information and to refuse any improper access to trade secrets and confidential information of any other company or entity, including our competitors. Company proprietary information must not be discussed with others within the Company, except on a strict need-to-know basis.
If there is a need to disclose Company trade secrets or confidential information to any person outside the Company, such disclosure must be done only in conjunction with an enforceable non-disclosure agreement. Similarly, the Company’s rights in its technology and products must be protected by use of appropriate agreements whenever such technology and/or products are used, transferred or disclosed.
You only may use logos, trademarks, service marks, brand names, copyrighted materials and other intellectual property owned by Sampled in accordance with the Company’s policies and not for personal use. In addition, employees must honor license agreements under which the Company is permitted to use computer software.
We protect the privacy of any personal data we collect, access, use, store, share or dispose of. Follow our policies as they relate to personal data. Only use personal information for legitimate business purposes. Always be transparent about the Company’s practices around personal data.
Protected Health Information
To the extent that Sampled collects and maintains patient information, all such information (e.g., personal identifying data, test results, payer data) must be held in the strictest of confidence and only should be accessed as professionally required to render appropriate services.
All employee information, including salary data, evaluations and personnel file information, is considered confidential and private. Employee information is only to be shared by and with authorized personnel. Employee personnel files are proprietary to Sampled.
Protect Our Information Technology Assets
These days, technology is the gateway into the Company’s information and operations. Unauthorized access to the Company’s IT systems could lead to the unwanted disclosure of confidential information or personal information. Similarly, unauthorized access to our systems also could severely impact our ability to operate as a business. It is everyone’s job to protect our IT systems. Never share your password with anyone. Never leave your Company assets unattended. Always watch for potential phishing or social engineering schemes. Do not open suspicious emails. Do not click on suspicious links. Do not authorize any financial transaction solely based on instructions that originate from a telephone call or email. Immediately contact IT if you suspect any unauthorized access, security incident or breach.
We ensure that all information about our Company that is shared publicly is accurate, complete, timely and consistent.
Communications with the Media, Regulators or Others
Do not make any public statements on Sampled’s behalf unless you have specifically been authorized to do so. Refer any media inquiry or contact by a government regulator to Sampled’s Executive Management team.
Public Speaking and Social Media
Obtain advance review and approval from the Legal Department of any materials you plan to use in connection with a work-related public speaking opportunity. Use good judgment and common sense when using both public and private social media platforms. Never disclose confidential information of the Company or that of our employees, customers, suppliers or other business partners on social media.
We expect prompt reporting of any known or suspected noncompliance with the Code, the Company’s policies or procedures, or applicable law.
Integrity is at the Core of our Reputation
This Code is not intended to be a comprehensive rulebook and cannot address every situation that you may face. If you feel uncomfortable about a situation or have any doubts about whether it is consistent with the Company’s standards, seek help. Speaking up when you need help understanding or following a policy, asking questions, and reporting potentially inappropriate behavior are all part of a healthy culture and the responsibility of every employee.
You are required to speak up if you suspect someone you work with, work for or contract with is in noncompliance with the Code, Company policies or procedures, or applicable law. You also are required to understand your obligations explained in the Code; make good-faith reports and cooperate fully with investigations; get help from the Compliance Department in person, via telephone or via email at email@example.com if you have questions; and ensure you never participate in any retaliatory conduct against employees who may raise concerns.
When to Report a Concern
All employees, officers and directors are required to report suspected noncompliance with this Code, the Company’s policies or procedures, or any applicable law by Sampled or any Company employee or agent. Employees are required to come forward with any such information without regard to the identity or position of the person or entity involved. The Company will treat the information in a confidential manner to the fullest extent possible. If you know of or suspect any noncompliance with this Code, the Company’s policies or procedures, or applicable law, you must immediately report your concern to your supervisor or manager, the Human Resources Department, the Legal Department, and/or the Legal Department as applicable, or by using the Helpline to share your observations and any facts, records or context that may help the Company to investigate the conduct.
Examples of possible concerns include, but are not limited to:
- Noncompliance with federal healthcare requirements or laws governing federal healthcare programs
- Any false or fraudulent claim for reimbursement submitted to the government for payment or approval
- Receipt of an overpayment from a federal healthcare program or on a government contract or subcontract
- Fraud, waste or abuse of Sampled or government resources
- Bribery or attempts to inappropriately influence government officials or other decision-makers
- Money laundering
- Retaliation against individuals speaking up in good faith
- Human rights violations
- Conflicts of interest
- Anti-Competitive behavior
- Disclosure or misuse of information
- Noncompliance with Public Health Service or other contractual requirements
- Inadequate or inaccurate financial or non-financial record keeping
- Non-compliance with a material term of a government contract or subcontract
How to Report a Concern
Sampled has established and is committed to maintaining an effective process for employees, officers, directors, contractors, consultants, agents and others to report, and for the Company to respond to and correct, any type of misconduct. If you encounter an ethics or compliance issue and you are not sure about the best course of action, you should ask for help.
The Company has established several methods by which you can report your concerns. You should discuss all issues, concerns, problems, suggestions and alleged, suspected or actual noncompliance with your immediate supervisors or other managers without fear of retaliation and with the assurance that the matter will be kept as confidential as possible.
You also may report suspected noncompliance directly to the Human Resourced Department at SampledHR@sampled.com, Legal Department at firstname.lastname@example.org and/or the Compliance Department at email@example.com as applicable. Employees also may report concerns using the Helpline online at www.lighthouse-services.com/sampled or by telephone at 1.855.222.0981. Helpline complaints may remain anonymous, and the confidentiality of the complaint will be protected to the fullest extent possible. The Sampled Helpline is available 24 hours a day, seven days a week, 365 days a year.
You should not conduct your own investigation of the suspected noncompliance prior to reporting it. Investigations will be conducted by appropriate designated personnel.
We Do Not Tolerate Retaliation
Speaking up can take courage and sometimes feel uncomfortable. The Company has zero tolerance for, and will not permit, retaliation of any kind against an employee for reporting potential ethics or compliance issues in good faith or for assisting in the investigation of these issues. Good faith does not mean that you need to be right or that your questions or concerns must have substantial facts to support it. Good faith requires only that the information you are providing is not fabricated or presented in any intentionally misleading manner.
Our non-retaliation policy is a cornerstone of this Code. If you are concerned about retaliation or believe that you have been subject to retaliation for reporting possible noncompliance or for participating in an investigation, you should immediately contact your supervisor, Human Resources, the Legal Department or the Compliance Department so that your concerns can be promptly addressed. Retaliation can be both obvious and subtle. Retaliation includes any adverse action taken against an employee for reporting a good faith concern about potential noncompliance with the Code, the Company’s policies or procedures, or any applicable law. Examples of retaliation include but are not limited to demotion, suspension, failure to consider for a promotion and/or creating a hostile work environment.
The Company will investigate any allegation of suspected wrongdoing and will take appropriate action at the conclusion of an investigation. Employees are required as a condition of employment to cooperate in any Company investigation, litigation or audit. The Compliance Department, the Legal Department or any persons assisting in the investigation are not lawyers or personal representatives for any employee. These persons are representatives of Sampled and are obligated to act in the Company’s best interests. Noncompliance with this Code, any Company policy or procedure, or applicable law will result in discipline, up to and including termination of employment, consistent with applicable labor laws. Additional information may be found in Sampled’s upcoming Speak Up Policy.
Sampled has established a Compliance Program to promote an organizational culture that furthers the Company’s commitment to conduct our business in compliance with all applicable laws and with the highest standards of business, medical, legal and personal ethics. The Compliance Program is led by the Chief Compliance Officer and overseen by the Board of Managers and the Corporate Compliance Committee, which provide support and guidance with respect to the design, implementation, effectiveness and enforcement of the Compliance Program. This includes executing all necessary actions to achieve the objectives of the Compliance Program, such as oversight of compliance-related training programs, assessment and review of potential compliance issues, and reinforcement of the Code and the Company’s policies and procedures.