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I. ETHICS AND VALUESOur Principles
Our PoliciesConflict of InterestMaintaining independence and impartiality is critical to the integrity and credibility of USP's standard-setting activities. Thus, all USP officers, trustees, volunteers, employees and representatives have an obligation to ensure that they remain free of actual or perceived conflicts of interest in the performance of their duties. Specific conflict of interest provisions applicable to USP trustees and volunteers are located in the Rules of Business Practice for the USP Board of Trustees and the Rules and Procedures of the Council of Experts. USP employees are expected to comply with the conflict of interest provisions set forth in the Employee Handbook. Gifts and GratuitiesAll USP officers, trustees, volunteers, employees and representatives shall conduct themselves so as to avoid giving the impression that they will give preferential treatment to any organization or individual or that they have not exercised independence or objectivity in carrying out their responsibilities. Therefore, such individuals shall not accept or retain anything of value for or because of any act performed or to be performed within the scope of their employment or volunteer duties. Except for items of nominal intrinsic value and reasonable business entertainment, USP officers, trustees, volunteers, employees and representatives shall not solicit nor accept any gift, gratuity, favor, entertainment, loan, or anything else of monetary value from an individual or organization that:
USP employees are expected to comply with the additional provisions and procedures relating to gifts and gratuities set forth in the Employee Handbook. Organizational RelationshipsUSP shall not enter into financial relationships with organizations whose principles, policies, or objectives conflict with USP's. USP may enter into financial relationships with other organizations only if the relationship does not pose a real or perceived conflict of interest and does not bias or appear to bias the objectivity and independence of the organization. USP may enter into a business arrangement with an organization whose products are subject to USP standards only if consistent with this policy and provided that the company provides a bona fide business product or service to the USP. Once USP enters into a business relationship with an organization that may otherwise be affected by USP activities, any USP employee involved in the transaction (including negotiation of the transaction) may not participate in standard setting, information development or other USP activities involving that organization. Donations of materials for development of reference standards may be accepted in accordance with the rules of the Reference Standards Committee. In order to obtain the highest quality material consistent with the purposes described in the monograph for which the reference standard is to be used, donations of materials for development of reference standards shall be sought first from the sponsor of the compendial monograph. Where it is not feasible to obtain materials from the sponsor, donations for development of reference standards shall be sought uniformly throughout the industry and multiple donors solicited when possible. Other donations, grants, sponsorships, and funding may be accepted consistent with this policy. USP shall not accept funding under any arrangement which would require USP to endorse, or appear to endorse, the products or services of the funding organization. Nor shall USP accept funding if a condition of receipt is that competitors not be allowed to participate in the program or project being funded. To the extent feasible, sponsorship of a particular event or activity should be from multiple sources. USP shall retain sole control over any program, publication, or other event sponsored by an organization that may be affected by USP standard setting or other activities. USP reserves the right to disclose all funding from organizations that may be affected by USP activities. Whistleblower and Non-Retaliation PolicyEach officer, trustee, volunteer, employee and representative of USP has an obligation to report all suspected questionable or improper accounting or auditing matters, violations of law, fraud, or other failures to comply with this Code of Ethics or related rules or procedures (Concerns). Such Concerns may be reported to an employee's supervisor, USP leadership, USP's General Counsel or the Chairperson of the Audit Committee. This policy is intended to encourage and enable officers, trustees, volunteers, employees and representatives to raise Concerns within USP for investigation and appropriate action. With this goal in mind, no officers, trustees, volunteers, employees and representatives who, in good faith, reports a Concern shall be subject to retaliation or, in the case of an employee, adverse employment consequences. This policy also prohibits retaliation against any individual who assists or participates in any investigation or proceeding relating to any alleged violation of any law, regulation, policy, or other rule or procedure. Moreover, anyone who retaliates against an officer, trustee, volunteer, employee or representative who has reported a Concern in good faith is subject to appropriate disciplinary measures up to and including termination. Anyone reporting a Concern must act in good faith and have reasonable grounds for believing the information disclosed indicates a basis for a Concern. The act of making allegations maliciously, recklessly, or with the knowledge that the allegations are false, will be viewed as a serious offense and may result in appropriate disciplinary measures. Employees may report Concerns to their supervisors or other USP leadership. In addition, anyone may report a Concern in one of the following ways:
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