ESG Code of Conduct Policy Statement

Upperton Pharma Solutions Code of Business Conduct

Upperton Pharma Solutions offer a wide range of strategy and consulting services for the pharmaceutical industry, including early phase clinical research, drug manufacturing, formulation development and data analysis services. 

We are regulated in the UK by the Medicines and Healthcare products Regulatory Agency (MHRA) and are committed to being a responsible and sustainable business that shows respect for the environment and communities in which we operate. We support and uphold the Ten Principles of the UN Global Compact and act to positively contribute to the UN Sustainable Development Goals.

A summary of our policy commitments in relation to core sustainability, and environment, social and governance (‘ESG’) issues, is as follows:

• Business Ethics: We always act with the utmost integrity and comply with all relevant legislation, anti-competitive practices including market-sharing, price-fixing, non-respect of confidentiality agreements, industrial espionage and abuse of dominant position are prohibited.
• Bribery and Corruption: In accordance with our Anti-Corruption and Bribery Policy, we prohibit corruption in all its forms, including bribery, extortion, fraud, embezzlement, money laundering and facilitation payments. Gifts and hospitality are not accepted if they are in any way thought or perceived to be in return for either doing/not doing something or showing favour/disfavour to a person or organisation.
• Community: We strive to positively contribute to our local community, engaging and supporting local charities.  
• Conflicts of Interest: Conflicts of interest and/or the appearance of a conflict of interest are actively avoided. Potential financial or non-financial conflicts of interest should be declared and are reviewed on a case-by-case base to determine and implement an appropriate course of action.
• Environment: We are committed to reducing our environmental impacts, notably those associated with energy use and reducing waste and water use and continually improving our environmental performance as an integral part of our business strategy and operating methods.
• Health and Safety: We regard the management of healthand safety as an integral part of our business and a management priority. In line with our Health and Safety Policy all activities and work will be carried out in a safe manner, in compliance with all applicable health and safety laws and regulations and we will ensure the health, safety and welfare of our employees and others who may be affected by our activities.
• Human Rights: We respect human rights and operate in accordance with the fundamental rights set out in the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work. This includes upholding freedom of association and collective bargaining, not using forced or child labour, and eliminating discrimination.
• Inclusion and Discrimination: In accordance with our EDI Policy, we are committed to promoting a working environment based on dignity and trust, where everyone feels respected and supported to reach their full potential. We provide equal opportunities in relation to all aspects of employment and work conditions. Direct discrimination, indirect discrimination, harassment, and victimisation in relation to age; disability (mental or physical); race, racial group, ethnic or national origin, or nationality; gender, gender identity or gender reassignment status; marriage or civil partnership status; political opinion; pregnancy and maternity; paternity, religion or belief; sexual orientation; educational background, socio-economic background, caring responsibilities, part-time or fixed-term status and worker representative organisations are all prohibited.   
• Information Security and Data Privacy: We are committed to safeguarding and protecting our information and any other information entrusted to us and we take cyber security issues very seriously. Upperton has a documented Information Security Policy in place which applies to all information system environments in our business. All employees are required to comply with the Policy and line management are required to ensure that they do. Training in security procedures and cyber security awareness is provided for all new employees and periodic updates take place for all staff.

We respect the confidentiality of all personal information shared with us and are committed to processing it responsibly and in compliance with applicable data protection laws.   External disclosure of confidential information is prohibited.

• Labour Standards: We pay equal and fair remuneration, including company bonuses linked to performance.  Employees are not expected to work more than 48 hours a week, receive far in excess of the ILO recommended paid holiday and we do not operate zero hours contracts.
• Flexible Working: We recognise the value of flexible working for our employees, and commit to careful consideration of all flexible working requests in line with our Flexible Working Policy.
• Modern Slavery: We are absolutely committed to preventing slavery and human trafficking in our operations and in our supply chains. This commitment is emphasised in our employee training programmes and company policies. We also expect the same high standards which we set for ourselves from those parties with whom we engage, such as our suppliers and customers.
• Political Lobbying: We do not give political donations and we prohibit lobbying in contradiction of the standards upheld in this Code of Conduct.
• Quality Assurance: We adhere to the highest standards of quality and patient safety in all aspects of our laboratory, development, and manufacturing operations.  Our Quality Management System guides our quality assurance work and is supported by an internal audit program that monitors compliance with applicable regulations, standards, and policies.
• Suppliers: We expect the highest standards of business ethics from suppliers and their agents in the supply of goods and services. We strive to work with our suppliers to seek and implement flexible and innovative ways to achieve our environmental, social, ethical and economic objectives.
• Tax: We are committed to being a responsible and compliant taxpayer in the UK and we do this through robust governance, not engaging in tax avoidance and being transparent in our relationship with the tax office. See link to our Criminal Offence Policy.
• Whistleblowing: We require all colleagues to maintain high standards of conduct. We encourage colleagues to report suspected wrongdoing as soon as possible in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected. See link to our Whistleblower Policy.

This Code of Conduct policy covers all employees, officers, consultants, contractors, volunteers, interns, casual workers and agency workers. Anyone who violates this Code, the law, or our policies may be subject to disciplinary action, up to and including termination, in accordance with applicable law.