Our Anti-Bribery and Anti-Corruption Principles
Capsugel colleagues conduct all Capsugel business in a lawful and ethical manner, in accordance with applicable laws and regulations, including the U.S. Foreign Corrupt Practices Act of 1977, the U.K. Bribery Act 2010 and similar anti-bribery and anti-corruption legislation. These laws prohibit making, promising, or authorizing the making of a corrupt payment or providing anything of value to a government official to induce that official to make any governmental act or decision to assist a company in obtaining or retaining business. It is also against the policy of Capsugel for any Capsugel colleague to engage in commercial bribery. Capsugel requires all of its consultants, agents and representatives, as well as companies acting on behalf of Capsugel (Business Associates) to conduct their Capsugel-related work in accordance with these principles.
To view Capsugel’s Code of Business Ethics, click here.
Corporate Responsibility and our Suppliers
Capsugel’s Code of Business Ethics applies in all countries where Capsugel conducts business. It is a guide to Capsugel’s ethics and compliance structure, applicable laws, and key policies and procedures that govern how we do business in a legal and ethical manner.
Our Code of Business Ethics states that Capsugel will not tolerate the use of unlawful child labor, slavery, human trafficking or forced labor in the research, manufacture, sale and distribution of our products. This is further supported by (i) Capsugel’s Supplier Code of Conduct, which sets forth Capsugel’s principles with respect to lawful and ethical conduct throughout its supply chain, including prohibitions against forced labor, as well as Capsugel’s expectation that its suppliers comply with these principles; and (ii) Capsugel’s Fair Labor Practices Policy, through which Capsugel employees are required to do the same.
Certain jurisdictions have enacted laws and regulations designed to promote transparency and to help eradicate slavery and human trafficking from companies’ supply chains. For example, the California Transparency in Supply Chains Act of 2010 requires certain companies to disclose activities in which they engage in furtherance of those efforts, focusing on: verification; audits; certification; accountability; and training. Similarly, the Modern Slavery Act 2015 in the United Kingdom requires businesses over a certain size threshold to disclose each year what action they have taken to ensure there is no modern slavery in their business or supply chains.
Set forth below is a summary of Capsugel’s applicable policies and procedures used to combat unlawful child labor, slavery, human trafficking and forced labor in the research, manufacture, sale and distribution of its products:
- Verification – Based on risk assessments, Capsugel distributes questionnaires to certain suppliers requesting that they disclose information about ethics and labor policies and environment, health and safety conditions at their facilities. Risk assessments are made based upon a number of factors, including the geographic location of the supplier.
- Audits – Based on the responses in the completed questionnaires mentioned above, Capsugel may require on-site audits of suppliers to assess their environment, health and safety conditions. Currently, Capsugel does not conduct formal audits of its suppliers’ compliance with applicable slavery and human trafficking laws, nor does Capsugel compare supplier compliance in this regard against any metrics.
- Certification – While no formal certification process is maintained, Capsugel’s standard purchase order terms require all of Capsugel’s suppliers to comply with all applicable laws in the performance of their services for the company, including laws regarding slavery and human trafficking.
- Accountability – To the extent permitted by law and contractual provisions governing termination rights, Capsugel reserves the right to terminate relationships with third parties, including suppliers, who conduct business in a manner that conflicts with Capsugel’s supplier requirements. Moreover, Capsugel’s ethics hotline provides a mechanism for employees and others to anonymously report potential violations of Capsugel’s Code of Conduct, its Fair Labor Practices Policy and applicable laws. Those who are found responsible for such violations may face disciplinary action, which may include termination of employment.
- Training – Capsugel employees globally receive training on Capsugel’s Code of Business Ethics and related corporate policies.
At Capsugel, we strive to produce consistent, strong financial results with integrity. Performance with integrity is about setting the right priorities, delivering on our commitments day-in and day-out, and adhering to our values.
As a privately held company, Capsugel makes its financial information and related disclosures available to anyone who has a clear need for access to it, including holders and beneficial owners of our Senior PIK Toggle Notes due 2019, as well as any prospective investors, securities analysts and market-makers in the instruments.
We communicate regularly with colleagues around the world about the importance of delivering these results with integrity and how their individual roles and behaviors contribute to these results every day. We also update our colleagues on a quarterly basis regarding the progress we are making toward our financial goals.
In addition to delivering strong financial performance with integrity, we provide insight about how we achieve our results. We hold earnings conference calls on a quarterly basis for those involved with our debt to review results with them and provide a forum for questions to be asked directly of our CEO and CFO. We maintain public credit ratings on our long-term debt with Standard & Poor’s Financial Services and Moody’s Investor Service. These ratings, which investors often use to help them make more-informed investment decisions, are available to anyone registered to receive the agencies’ financial research and analysis. We’ve also appointed an Internal Audit Director whose responsibilities include evaluating existing risk management policies and controls (including controls over our financial statements), suggesting improvements where necessary, and then overseeing their implementation.
Identifying potential emergencies and other business impacts is essential to minimizing business interruptions and ensuring consistent delivery of our products and services to our customers. To that end, we have worked to anticipate the potential effects of significant business interruptions, and developed continuity and disaster recovery plans to effectively respond to them in ways that limit their impact on our business, our colleagues and our customers.