1. Policy purpose
1.1. CROss Alliance® (CRO) is the brand name for the company CROSS Research SA acting as Contract Research Organization (CROs) and specialised in the planning, management research and development of new medicinal products, medical devices, food supplement on behalf of Sponsors.
1.2. CROSS Research company approach to business is guided by commitment to Transparency, Integrity, Leadership and Continuous Improvement.
1.3. Concern for the environment and sustainability are values recognised and promoted by CROSS Research company.
1.4. This policy summarises CROSS Research commitments regarding these values as well as our respect for ethics.
1.5. CROSS Research (sub)contractors are made aware of this Policy and must agree to comply with it in their collaboration with CROSS Research.
1.6. CROSS Research Management is responsible for providing necessary support to employees so that they understand and apply what is required by this Code.
2. Correct information, accounting and reporting
2.1. In case of request (e.g. inspections, fiscal audits, due diligence), CRO acknowledge to disclose its business information. In such cases, CRO business information will be communicated to the authorized recipient, accurately and covering fully the purpose of the activity.
2.2. All accounting information must be correct, registered and reproduced in accordance with laws and regulations, including relevant accounting standards
3. Fair competition and anti – trust laws
3.1. CRO will compete in a fair and ethically justifiable manner within the framework of the anti – trust and competition rules in the markets in which operates.
4. Corruption, bribery and kickbacks
4.1. CRO is against all forms of corruption. For the purpose of this code, corruption includes bribery and trading in influence. These includes the public and private sectors. The code makes a special mention of facilitation payments, stressing that the CRO is against the use of this type of payment even in cases where it may be legal and will work actively to prevent such payments. In addition, the code states that third parties working with the CRO have to adhere to the same rules and procedures.
4.2. The prohibition against corruption described above applies for individuals acting on CRO behalf.
4.3. The CRO offers its services on an impartial and objective basis, free from outside influence. Employees are not allowed to offer, give, solicit or receive any form of kickback.
4.4. For additional information please refer to United Nations Convention against Corruption (UNCAC) guideline.
5. Gifts, hospitality and expenses
5.1. Employees and persons acting on behalf of CROSS Research must not accept gifts except for promotional items of minimal value. Hospitality such as social events, meals or entertainment, travel expenses are accepted only if there is a clear business reason among the respective companies. No individual acting on behalf of the CRO may, in their dealings with customers, suppliers and other parties, offer or agree to pay for gifts, hospitality or other expenses that would violate the above described principles.
6. Conflict of interest
6.1 The individual must behave impartially in all business dealings and not give other companies, organisations or individuals improper advantages. The individual must not become involved in relationships that could give rise to an actual or perceived conflict with the CRO interests or could in any way have a negative effect on their own freedom of action or judgement.
7. Public officials
7.1. The code prohibits employees from giving gifts, payments or offering anything of value to public officials.
8. Relations with suppliers, partners and customers
8.1. Suppliers and partners are expected to adhere to ethical standards, which are consistent with the CRO Code of Ethics.
9. Government Relationships
9.1. No CRO employee is involved in any business relationship, including acting as an agent or consultant for, or holding common ownership of any business enterprise or partnership with any current Government Official (or close family member) of any government, including any government ministry, agency, or government-owned or controlled entity (such as a government-owned company)
9.2. No CRO employee is in a position (directly or indirectly) to exercise influence over the decisions of any government or government-owned or controlled entity (such as a government-owned company), including by virtue of holding a leadership position in a political party.
9.3. No government, government agency, government-owned organization, or other organization performing a governmental function own any interest or exercise any control over the CRO.
10. Debarment & Sanctions List Presence
10.1. The CRO (including any of its employees) has never been debarred to any government entity.
10.2. The CRO (including any of its employees) is not currently listed on a Sanctions or Watch List.
11. Use of intermediaries
11.1. Before intermediaries (for example, lawyers or consultants) are hired, it must be ensured that the intermediary’s reputation, background and abilities are appropriate and satisfactory. The CRO expects that intermediaries act in accordance with its ethical requirements and this condition should be included in the intermediary’s contract or alternatively this Ethical Code of conduct signed for acceptance.
12. Equality and diversity
12.1. The CRO will show respect for all individuals and make active efforts to ensure a good working environment characterised by equality and diversity.
13. Insider information
13.1. Irrespectively of how the information is obtained, no individual may use, or contribute to others using, insider information about the CRO or its clients/partners to subscribe for, or trade in, securities, either privately or on the CRO behalf.
14. Retaliation
14.1. The CRO has zero tolerance policy on retaliation. Any CRO employee will be shielded from retaliation.
14.2. It an employee voice a concern or report misconduct in good faith – or take part in an investigation of an ethics and compliance matter under no circumstances retaliation will be accepted.
14.3. The CRO consider acts of retaliations to be acts of misconduct which, if substantiated, could result in disciplinary action and even dismissal. Retaliation can take many forms like being ignore, being unfairly dismissed, being bullied with the aim of stopping the employee from reporting a potential ethical breach, demotion, suspension, failing to hire or consider for hire or promotion, failing to give equal consideration, adversely impacting working conditions or otherwise denying any employment benefit to an employee, creating a hostile or intimidating work environment.
14.4. All employees are required to report any suspicion of improper or wrongful activity to the Corporate Management.
15. Sexual Harassment
15.1. The CRO is committed to providing a safe environment for all its employees free from discrimination on any ground and from harassment at work including sexual harassment.
15.2. Sexual harassment is unwelcome conduct of a sexual nature which makes a person feel offended, humiliated and/or intimidated. It includes situations where a person is asked to engage in sexual activity as a condition of that person’s employment, as well as situations which create an environment which is hostile, intimidating or humiliating for the recipient.
15.3. All sexual harassment is prohibited whether it takes place within the CRO premises or outside, including at social events, business trips, training sessions or conferences.
15.4. All employees are required to report any suspicion of sexual harassment to the Corporate Management.
16. Reporting Misconduct
16.1. All employees shall conduct business in a manner consistent with the highest legal and ethical considerations. They are required to promptly report to the Corporate Management any concerns relating to unethical conduct, violation or potential violation of applicable law, regulation or this policy.
17. Employee, Client and Vendor Information
17.1. The CRO will treat Employee, Client and Vendor Information according to the highest confidentiality standards.
18. Deontology and Patients’ Safety
18.1. The CRO will operate in compliance the applicable laws and guidelines related to the Clinical Research for example ICH-GCP and the ethical principles of the Declaration of Helsinki.
18.2. The CRO aims to guarantee the scientific and research ethical principles of each study, performed only after obtaining the authorization from Competent Authorities and Ethic Committees.
18.3. The CRO aims to ensure that the persons who take part in the clinical research are not exposed to useless risks, that all information related to the nature and the objective of the studies are easy to understand, that the procedures required to obtain informed consent are complied with and that suitable confidentiality rules be applied.
18.4. The CRO aims to ensure that data obtained in research projects are obtained and processed in their all life-cycle in accordance with current regulations and applicable data-integrity and quality standards.
19. Data Protection
19.1. The processing of personal data by the CRO shall always be in line with the EU General Data Protection Regulation (GDPR; Regulation EU 679/2016), and the applicable Swiss data protection regulations (Swiss Law 235.1, Federal Act on Data Protection of June 19th, 1992). Further details are available on the CRO Privacy Policy.
20. Sustainability Policy
20.1. The CRO aims to follow and to promote good sustainability practice, to reduce the environmental impacts of all its activities and to help its clients and partners to do the same.
20.2. For this reason the CRO intend:

  • To integrate sustainability considerations into all its business decisions.
  • To ensure that all employees are fully aware of our sustainability policy and are committed to implementing and improving it.
  • To minimise the impact on sustainability of all office and transportation activities. When selecting transport to attend meetings, site visits etc., the lowest environmental impacting system will be selected unless impractical and/or cost prohibitive.
  • To avoid physically travelling to meetings etc. where alternatives are available and practical, such as using teleconferencing, video conferencing or web cams, when not sacrificing the benefits of regular contact with clients and partners.
  • To minimise our use of paper and other office consumables, for example by double-siding all paper used, standard printing in black and white (set by default) and not use colours unless strictly necessary, recycling paper for temporary internal drafts and identifying opportunities to reduce waste.
  • To commit to waste reduction in the following order: reduce, reuse, and then recycle (as far as possible) paper, computer supplies and redundant equipment.
  • To reduce the energy consumption of office equipment by purchasing energy efficient equipment (e.g. better energy class).
  • To take into due consideration the energy efficiency of hardware when buying new IT systems.
  • To progressively switch to energy-efficient bulbs and low impact light systems (e.g. LED lamps) whenever possible.
  • To invite employees to turn off lights when leaving rooms.
  • To invite employees to turn off computers when not used.
  • To invite employees to choose stairs and not the elevator to access and leave the company offices (at least when going down).
  • To invite employees to think twice before printing documents unless really needed for work efficiency or business/regulatory need.
  • To put photocopy machine in energy saving mode when not in use.
  • Verifying yearly the power consumption trying to maximise the efficiency.
  • To limit the waste of water in all its offices.
  • To properly dispose batteries, and adopt the best methods for waste disposal (e.g. glass, paper, metal etc.) as possible within the local regulations and town instructions.
20.3. The above recommendations are extended to individuals acting on behalf of the CRO.