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III. MANAGEMENT PROCESSES

USP Principles

• USP will design, implement, and maintain quality assessment programs to continuously monitor, improve, and measure the quality and impact of USP programs and services
• USP will manage its finances in accordance with sound financial principles and maintain accurate records that ensure full, fair, timely, and understandable financial disclosure
• USP will comply with all applicable laws and regulations affecting its activities
• USP will apply a comprehensive, continuous enterprise risk management process to ensure that risks affecting the organization are appropriately identified, evaluated, managed, and reported

USP Policies

Quality Policy

USP promotes public health by establishing and disseminating officially recognized standards of quality and authoritative information for the use of medicines and other healthcare technologies by health professionals, patients and consumers. USP, operating under a rigorous quality management system and practices, is committed to providing quality products and services to our customers, volunteers, and stakeholders, with the goal of having the quality of such products and services to be considered outstanding worldwide.

Financial Reporting and Record-Keeping Policy

USP is committed to ensuring that all internal and external reports and records USP creates, makes public, or provides to the government constitute full, fair, truthful, timely, and understandable disclosures, and do not contain false, misleading, or inaccurate statements. Such records and reports serve a critical role in managing USP's business, in fulfilling its obligations to its customers, suppliers, and the government, and in maintaining open and honest communications with members, volunteers, employees, stakeholders, and the public.

USP maintains accounting and internal control and audit systems to ensure the accuracy of its financial statements and records. All financial information shall conform to generally accepted accounting principles and established USP financial policies and procedures. All transactions and disbursements shall be reported accurately, completely, and in appropriate detail in order to ensure full accountability for all assets and activities of USP and to supply the data needed in connection with the preparation of its financial statements. Any concerns regarding the accuracy or integrity of financial reporting or deviations from established financial policies should be brought to the attention of the Chief Financial and Administrative Officer or otherwise reported in accordance with USP's Whistleblower and Non-Retaliation Policy.

Use of Company Assets

It is the responsibility of all USP employees, officers, trustees, and volunteers to preserve and protect USP assets, including time, equipment, materials, supplies, and information, and take all reasonable actions to prevent loss of company assets through carelessness, theft, or waste. The confidentiality of USP's proprietary information shall be maintained at all times in accordance with USP's confidentiality policies, rules, and procedures.

USP resources are to be used only for their legitimate, intended business purposes. No employee, officer, trustee, or volunteer shall use USP property, information, or his or her position with USP in any way that is, or appears to be, motivated by private gain or to compete with USP, or take personal advantage of any business or financial opportunity that properly belongs to USP.

Compliance with Laws, Rules, and Regulations

All USP employees, officers, trustees, volunteers, and other agents and representatives are expected to comply fully with all laws, rules, and regulations affecting USP's operations in the United States and in all other countries in which USP conducts its activities. Employees are expected to be aware of and have an understanding of all laws, rules, and regulations that relate to their USP functions and responsibilities, and to adhere to all applicable USP procedures to ensure compliance with such laws. Because the laws that are applicable to USP are often very complex and penalties for violations may be severe, any questions or concerns should be brought to the attention of the Legal Department, or appropriately reported pursuant to USP's Whistleblower and Non-Retaliation Policy.

International Activities and the Foreign Corrupt Practices Act

As an organization that provides products and services globally, USP must abide by the laws of all countries in which it operates, including those that govern its international activities. The U.S. and many governments have laws and regulations that restrict trade and business transactions with other countries, including restrictions on exports and imports of certain goods, technology, and services. Employees involved in such transactions shall adhere to all applicable USP procedures to ensure compliance in this area.

USP's employees, officers, trustees, volunteers, and other agents and representatives are also required to comply with the U.S. Foreign Corrupt Practices Act and comparable laws in other countries. Accordingly, USP's employees, officers, trustees, volunteers, and other agents and representatives may not directly or indirectly engage in bribery, kickbacks, payoffs, or other corrupt business practices, including offering or giving government personnel anything of value for the purposes of influencing them to misuse their official capacity or to gain an improper advantage. USP employees and representatives involved in international operations must be familiar with these laws and adhere to all USP procedures relating to these laws. Any suspicion that a payment is being used for such improper purposes should be immediately reported to USP management or in accordance with USP's Whistleblower and Non-Retaliation Policy.

Intellectual Property

USP's policy is to respect patents, trademarks, and copyrights owned by others, and to strictly adhere to all relevant laws and regulations regarding such patents, trademarks, and copyrights in the U.S. and other countries, including laws and regulations relating to the use and copying of protected material. Photocopying of copyrighted materials is permitted only if such materials are covered by USP's Copyright Clearance Center license or such photocopying is otherwise allowed under USP's copyright procedures.

USP is also committed to defending its own copyright and trademark rights in the U.S. and elsewhere. USP's name and trademarks may be used by employees, licensees, and distributors only in accordance with applicable USP procedures.

Any questions regarding the intellectual property rights of USP or third parties should be directed to the Legal Department.