Code of Conduct

Code of Conduct


Disruptive Pharma believes in social and environmental responsibility and ethical conduct, and expects its employees and business partners to do the same. Disruptive Pharma is being developed with long-term sustainability in mind, which also includes building sustainable relationships with our business partners.

Furthermore, Disruptive Pharma and its business partners have an obligation to all stakeholders to observe high standards of integrity and fair dealing. This is the foundation for, and the reason why, Disruptive Pharma has created the Disruptive Pharma Code of Conduct. Our policies and the Disruptive Pharma Code of Conduct are further based on:

  • UN Universal Declaration of Human Rights and connected UN Conventions
  • ILO Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy
  • OECD Guidelines for Multinational Enterprises
  • UN Global Compact

Who does the Disruptive Pharma Code of Conduct apply to? 

The Disruptive Pharma Code of Conduct applies to all our employees and business partners that provide products or services to Disruptive Pharma, or that are engaged or instructed to act for or on behalf of Disruptive Pharma, such as suppliers (and subcontractors if used while engaging with Disruptive Pharma), consultants, distributors, agencies, and other representatives.

Legal compliance

Disruptive Pharma requires all our employees and business partners to operate in accordance with the principles in the Disruptive Pharma Code of Conduct, and in full compliance with all applicable laws and regulations. The Disruptive Pharma Code of Conduct does not replace legislation, and if the two are in conflict, legislation takes precedence. If the Disruptive Pharma Code of Conduct sets a higher standard than the existing legislation, the reverse applies.

Raising concerns

Should you, or if you are a business partner, your employees, believe that the terms of the Disruptive Pharma Code of Conduct are not adhered to, or that Disruptive Pharma is not acting in accordance with the Disruptive Pharma Code of Conduct, then we encourage you to raise your concerns to Disruptive Pharma Headquarters.

Implementation and monitoring

Disruptive Pharma monitors the implementation and adherence of the Business Partner Code of Conduct. Disruptive Pharma will assess its business partners’ compliance with the Business Partner Code of Conduct. Violations will be handled immediately, and any violations of the Business Partner Code of Conduct may jeopardize the business partner’s business relationship with Disruptive Pharma, up to and including termination.

Business ethics


Disruptive Pharma respects the laws and regulations of the countries in which it operates, and requires that its business partners do the same. Disruptive Pharma does not tolerate any form of corrupt activities, including but not limited to bribery, conflicts of interest, fraud, extortion, embezzlement, and unlawful kickbacks, and its employees or business partners shall not engage in, or cause Disruptive Pharma to engage in, any form of corrupt activities.

Competition and antitrust laws

Disruptive Pharma’s employees and business partners shall comply with all applicable competition and antitrust laws and regulations. This means, among other things, not to engage in price fixing, market sharing, bid rigging, or customer allocation.


Disruptive Pharma does not accept bribes or facilitation payments in any form.

Conflict of interest

Conflict of interest between a business partner and Disruptive Pharma must be avoided. Conflicts of interest may include external business activities, personal financial interests, internal information, and employment of, buying from, and selling to family members and close personal friends. Furthermore, Disruptive Pharma expects you, in your business interaction with Disruptive Pharma, to protect all confidential information provided by Disruptive Pharma and respect the intellectual property of Disruptive Pharma and others.

Human rights & labor standards

Child labor

Disruptive Pharma recognizes the rights of every child to be protected from economic exploitation, and from doing work that is likely to be hazardous to their physical, mental or spiritual health, harmful to their moral or social development, or to interfere with their education.

A child in this context is a person who is less than 15 years of age, or less than 14 years of age in accordance with the exceptions for developing countries as set out in Article 2.4 in the ILO Minimum Age Convention (No. 138). If relevant national legislation has set a higher minimum age, then this age will apply. Some countries apply the definition of “young workers” to persons above the minimum age and less than 18 years of age, which means that there might be legal restrictions regarding the type of work that they are allowed to perform.

Disruptive Pharma does not tolerate the use of child labor, and expects the same from its business partners. However, Disruptive Pharma acknowledges that child labor exists, and realizes that it cannot be eradicated by simply setting up rules or inspections. If a child is found producing products or providing services for Disruptive Pharma, it is requested that the employer acts in accordance with the overall best interest of the child. In such cases, business partners are expected to cooperate in seeking a satisfactory solution that will improve the individual child’s overall situation, with the child’s age, social situation, and education always taken into account before a decision is made.

Forced or bonded labor

Disruptive Pharma does not tolerate the use of any form of forced or bonded labor, including employment of prisoners or illegal workers, and expects its business partners to do the same. Disruptive Pharma acknowledges that forced or bonded labor can include requiring a deposit of payment, or demanding a deposit of identity documents or other personal belongings, all of which is prohibited. If business partners employ foreign workers on a contract basis, the workers must not be required to remain in employment against their will, and they shall further have the same rights as local workers. The employer will pay for commissions and recruitment agency fees in connection with the employment where applicable.

All workers shall have the right to leave their workplace and accommodation (if provided) freely during the hours in which they are not working.

Freedom of association and collective bargaining

Disruptive Pharma expects its business partners to respect the rights of its employees in having the freedom to join, or not to join, an association of free choice, as well as establish an association of free choice, to organize, and to bargain collectively or individually in accordance with local laws and regulations. No employee should risk being harassed or retaliated against for exercising these rights.

Workers’ contracts, working hours and compensation

Disruptive Pharma expects its business partners to comply with local laws and regulations regarding workers’ contracts and working hours, including overtime and overtime compensation. Salaries should be paid regularly and comply with the applicable local legislation and local market situation. Workers should be entitled to a minimum of one day off in seven, as well as time off for established national and local public holidays. Workers should be granted the stipulated annual leave, sick leave and maternity/paternity leave without any negative repercussions.

Discrimination, harassment and diversity

Disruptive Pharma values and promotes diversity and gender balance. Disruptive Pharma expects its business partners to provide a work environment where everybody is treated with respect and dignity, and given fair and equal opportunities for development. Disruptive Pharma does not tolerate any form of discrimination or harassment in the workplace, and our business partners shall not discriminate against any worker based on race, ethnicity, sexual orientation, gender, religion, age, disability, political opinion, nationality, or any other potentially discriminatory factor.

Alcohol and/or drug abuse

Disruptive Pharma works proactively to remove any workplace hazards. Individuals producing products or providing services for Disruptive Pharma should not be on company premises or in the workplace if they are under the influence of, or adversely affected by, alcohol, to the extent that this impairs the individual’s ability to perform their work duties. Disruptive Pharma has zero tolerance for the use of illegal drugs, and does not allow individuals producing products or providing services for Disruptive Pharma to be on company premises or in the workplace if they are under the influence of illegal drugs.

Consumer interest

Disruptive Pharma requires that applicable health and safety requirements are met for its products and services, and our business partners shall take this into account when producing goods or providing services for Disruptive Pharma.

Responsible sourcing of minerals

Disruptive Pharma is committed to complying with relevant laws and regulations requiring the disclosure of the use of conflict minerals. Conflict minerals are minerals from high risk and conflict-affected areas that have directly or indirectly contributed to financing of armed groups, where some groups are believed to be responsible for serious human rights violations. Goods provided to Disruptive Pharma shall be in compliance with relevant laws and regulations regarding conflict minerals


Environment and sustainability

Disruptive Pharma shall meet legal environmental requirements and expects its business partners to obtain, keep current, and comply with all required environmental permits and licenses needed for their operations. Disruptive Pharma encourages the development and diffusion of environmentally friendly technologies. Disruptive Pharma recommends that all business partners with significant environmental impact implement certifiable environmental management systems or similar systems that facilitate the business partners’ work with the environment.

Disruptive Pharma continuously seeks ways to reduce the consumption of resources. Disruptive Pharma expects its business partners to strive to reduce their consumption of resources, including energy and water, to reduce their production of waste and pollution, to keep acceptable noise levels, and improve the overall environmental impact of their operations and products along the value chain. Further, chemicals and hazardous materials shall be labeled properly and safely stored, and recycled, reused, and disposed of correctly.

Health & safety

Work environment

Disruptive Pharma works systematically with health and safety, and is committed to provide a safe work environment, and expects its business partners to do the same. Risks that can cause accidents or impair the health and well-being of individuals while working for Disruptive Pharma shall be reduced. Therefore, occupational health and safety hazards shall be identified, evaluated and managed through a prioritized process of hazard elimination, engineering controls, and/or administrative controls.

For Disruptive Pharma, a safe work environment means, for example, that work areas are kept clean and free from pollution, machines used in production are safe and do not risk the health of the workers, and instructions regarding the use of personal protection and work equipment are adhered to. Personal protective equipment and work equipment shall be provided to the workers. Further, the work environment shall be well lit, and have temperature and noise at acceptable levels. When noise is above acceptable levels, personal protective equipment such as ear protection shall be used. Disruptive Pharma also expects the above from its business partners.

Building and fire safety

Hazardous material and equipment must be stored according to applicable law. There should be clearly marked emergency exits in all workplaces. Exits must not be blocked and should be well lit. All workers shall receive information about safety arrangements, such as emergency exits, fire extinguishers, first aid equipment, etc. An evacuation plan should be displayed on each floor of a building. The fire alarm should be tested and evacuation drills carried out on a regular basis.

First aid and medical care

First aid equipment must be available at appropriate locations, and at least one person in each location should be trained in basic first aid. The business partner should cover the costs of medical care for injuries incurred on its premises if they are not covered by social security or insurance, provided safety rules have not been violated.

Security, theft and waste

The purpose of our security requirements is to protect Disruptive Pharma property and systems, and reduce the risk of illegal intrusion, sabotage, damage, disruption, data intrusion, or other action that may lead to any form of loss.

Information security refers to material and equipment, as well as information and knowledge. It is the responsibility of all employees to maintain a high standard of security, which includes controlling and managing passwords and PIN codes to computers and mobile phones, and using our communication systems when processing, sending, receiving, storing, printing, or in any other way, sharing information that is false, illegal, harassing, or not compliant with professional behavior.

Any form of crime, such as theft, waste, embezzlement, fraud, blackmail or receipt of bribes is unacceptable and can lead to disciplinary action, such as written not or dismissal. Any such violations within Disruptive Pharma will be reported to the police or other appropriate authority.