Fitgenes Pty Ltd Code of Conduct & Ethics

 

1. Introduction

Fitgenes Pty Ltd (“Fitgenes Pty Ltd” or “Company”) is committed to:

  • being a company respected for integrity in all its dealings
  • being an employer that provides opportunity and reward in an environment of trust and respect
  • earning the trust of stakeholders
  • being respected in the communities where it does business
  • conducting its business in a way that is accountable to stakeholders  and the wider financial marketplace

The reputation and integrity of Fitgenes Pty Ltd relies on its Certified Practitioners observing a high standard of behaviour in the delivery of “patient services” using the Fitgenes brand and in its treatment of its employees.

“Patient services “ are professional practitioner services provided to Patients by Fitgenes Certified Practitioners using the Fitgenes Brand embodied in the use of PRACWARE and the Practitioner Web portal and the use of the Fitgenes website and abiding by this code of conduct and ethics.

By definition the “Fitgenes brand” is Intellectual Property comprising Fitgenes propriety business processes and content in all its forms.

 

2. Purpose of the Code

This Code of Conduct (“Code”) provides a common behavioural framework for all Certified Practitioners in the conduct of Fitgenes Pty Ltd business, irrespective of their specific role, or location in the world.

It is a key part of the Fitgenes Pty Ltd culture. It sets out the standards for our relationships with customers, Certified Practitioners, employees, Patients, suppliers, competitors, clinical trial participants, research collaborators and the community.

All Certified Practitioners are bound by the Code and are expected to comply with the Code when representing the Company.

The objective of the Code is to ensure that high standards of corporate and individual behaviour are observed by all Certified Practitioners in the context of their engagement with Fitgenes Pty Ltd and in delivery of patient services.

For the purpose of this document "Certified Practitioners" includes Certified Practitioners, its employees, and its subsidiaries and each of their contractors and directors.

 

3. General principles

3.1 Certified Practitioners will conduct themselves with integrity at all times.

3.2 Fitgenes Pty Ltd will apply appropriate industry practices to the health, safety and wellbeing of its employees, customers, suppliers, Certified Practitioners, patients, clinical trial participants and the communities in which it operates

3.3 Certified Practitioners will apply appropriate industry practices to the health, safety and wellbeing of its employees, customers, Patients, suppliers, clinical trial participants and the communities in which it operates.

3.4 Certified Practitioners will strive to ensure their words and actions show respect for the diverse range of people and cultures with whom they work with and the patients they serve.

3.5 Fitgenes Pty Ltd and its Certified Practitioners will exercise due care and diligence in the performance of their duties and responsibilities.

3.6 Certified Practitioners will exercise due care and diligence in representing Fitgenes Pty Ltd  core values and providing professional patient services in accordance with our core values and ethics.

 

4.0 Core Values and Ethics

Fitgenes core values:

To excel in global Research into Nutrigenomics and Personalised Intervention Based in Genetic Profiling.

To educate and train “Health and Wellbeing” Practitioners in the provision of leading personalised health intervention strategies, programs and services that are targeted to meet the Patients health goals.

Ethics:

The Practitioner must at all times in the conduct of providing professional services:

  1. Ensure that any recommended supplementation meet the minimum efficacy standards as approved  by Fitgenes Pty Ltd
  2. Not misrepresent or exaggerate the potential health or lifestyle outcomes to a patient for financial gain.
  3. Recognise that information and advice provided to you by Fitgenes is dynamic and based on the rapidly evolving DNA research world; so if in doubt regarding providing patient services, call our Fitgenes Science Representative for specific advice.
  4. Comply with all Fitgenes most recent policies as displayed on the Website or included in the Pracware license agreement.
  5. Supply professional advice to Patients in accordance with best industry practice;
  6. Meet the Fitgenes Accreditation Criteria at all times
  7. Maintain strict patient information privacy as required by best Health and Medical Practitioner Industry Practice
  8. Not provide Pracware login and password access to any other third party without written permission from Fitgenes Pty
  9. Conduct themselves at all times in a manner that reflects the core values of Fitgenes

 

5. Obligation to comply with Code

Certified Practitioners will adhere to the Code both in letter and in spirit.

Fitgenes reserves the right to revoke your accreditation and any license agreements, if Fitgenes Pty Ltd suspects you have breached this code of conduct.

Violation of the Code by any Certified Practitioner or its employees, or unethical behaviour which may affect the reputation of Fitgenes Pty Ltd may be subject to disciplinary action including termination of any agreements with Fitgenes Pty Ltd.

 

6. Integrity

All Fitgenes Pty Ltd' Certified Practitioners are expected to conduct business in a manner that enhances the Company's reputation and integrity. The overriding principles which govern behaviour and business dealings are:

6.1 Local Law: Business will be conducted in accordance with the laws and regulations of the

countries in which Fitgenes Pty Ltd operates.

6.2 Competition: Fitgenes Pty Ltd and its certified practitioners will compete fairly in the markets in which it operates.

6.3 Corrupt practices: Corrupt practices are unacceptable. Commercial transactions

will be properly and accurately recorded

6.4 Conflicts of interest: Certified Practitioners will disclose to the Company any activities that involve, or could appear to involve, a conflict between their personal interests and the interests of

Fitgenes Pty Ltd. Areas where conflicts might arise include: ownership interests in businesses with

which Fitgenes Pty Ltd deals, share ownership, directorships of other companies direct or indirect

personal interest in contracts, seeking or accepting gifts or entertainment beyond levels

considered reasonable in the business environment, engagement outside of Fitgenes Pty Ltd or

use of confidential information. Where a conflict of interest arises or may arise, an Certified Practitioner must disclose the conflict to  the company.

6.5 Corporate opportunities: Certified Practitioners will not compete with Fitgenes Pty Ltd or take improper advantage of their position for personal gain.

6.6 Confidentiality: Certified Practitioners will not breach Fitgenes Pty Ltd's confidentiality or make use of confidential information obtained from Fitgenes Pty Ltd for personal gain or in a manner which would be detrimental to Fitgenes Pty Ltd. Confidential information of Fitgenes Pty Ltd is not to be used except in ways which are authorised by Fitgenes Pty Ltd or legally mandated. The same applies to confidential information belonging to third parties which an certified practitioner may obtain in the course of their duties. Fitgenes Pty Ltd will respect the confidentiality of its Certified Practitioners.

6.7 Conduct of Clinical Trials: Company sponsored clinical trials will adhere to the principles of

Good Clinical Practice. Certified Practitioners shall abide by the same principles.

6.8 Email: Certified Practitioners are responsible for using the Company’s email and internet resources responsibly and for Company use. All communications and information transmitted by,

received from or created or stored in the Company’s information systems are the Company’s

records and property and may be monitored and read by management without notice to

Certified Practitioners subject to applicable laws.

6.9 Certified Practitioner Engagement practices:

Certified Practitioners should feel that they can discuss, on a confidential basis, any problem associated with their engagement with the Company.

 

Certified Practitioners Engagement practices shall include:

6.9.1 Occupational health and safety:

The Certified Practitioner is committed to providing a safe and healthy working environment and to working with contractors and suppliers that also operate a safe and healthy work environment. Certified Practitioners can only provide a healthy and safe working environment with the cooperation of every employee.

 

As part of that cooperation Certified Practitioners

must:

  • Acquaint themselves with the requirements of all applicable occupational health andsafety laws.
  • Apply appropriate practice in our industry with regard to safety and health.
  • Regularly review risk management systems to properly identify, control and prevent accidents in the workplace.
  • Safety procedures should never be compromised to meet operational targets.

 

6.9.2 Non-discrimination and sexual harassment: Fitgenes Pty Ltd is an equal opportunities employer. The Company is committed to developing an appropriately qualified and experienced

workforce, and providing a work environment in which everyone is treated fairly and with

respect, irrespective of gender, nationality, sexual orientation, age, marital status, disability,

political opinion, religion or ethnic/social origin. The company expects that the Certified Practitioner abide by these values.

 

6.9.3 Creating an environment where everyone is encouraged to give their best.

6.9.4 Freedom of association: Fitgenes Pty Ltd respects the individual's right to freedom of association and expects the Certified Practitioner to abide by the same values.

6.9.5 Creating an environment where the Certified Practitioners employees can discuss any problems connected with their work confident that they will receive a fair, impartial and confidential review of the issue.

 

7. Responsibilities to the community:

7.1 Environment: Fitgenes Pty Ltd values the natural environment and is committed to sound environmental practices in our operations. Fitgenes Pty Ltd Certified Practitioners are asked to take a thoughtful approach to environmental risk management.

The Company is required to comply with relevant environmental laws and regulations and adopts the following principles:

  • Thorough understanding of all relevant environmental laws, regulations and industry best practice relevant to the Company’s areas of operation.
  • Responding to community concerns with respect and integrity.

7.2 Human rights: Fitgenes Pty Ltd supports the principles contained in the Universal Declaration on

Human Rights. In particular Fitgenes Pty Ltd will not tolerate child labour or forced labour in the

Company’s operations or those of our suppliers and and our Certified Practitioners.

7.3 Animal Welfare: The development of new pharmaceutical products is a highly regulated

process, controlled on an individual country by country basis. Government agencies enforce

stringent efficacy and safety testing standards that must be attained before pharmaceutical

products can be administered to humans. These government mandated safety and efficacy

standards include testing in non-human species.

 

Fitgenes Pty Ltd seeks to minimize the number of tests it conducts involving animals.

The Company’s tests for efficacy and safety are conducted in a number of third party facilities and the operations of these facilities are regulated by local laws. Such regulation typically includes oversight of tests by an ethics committee responsible to ensure the tests are justified on a technical and ethical basis, and that the facility fully complies with local standards for the conduct of such tests.

 

8. Reporting violations of the code of ethics or other unethical conduct

Trust and integrity are vital to Fitgenes Pty Ltd. Misconduct and malpractice breach trust and endanger our reputation and business.

The best way of protecting trust is for our Certified Practitioners and its employees who have genuine suspicions about wrongdoing to know they have a safe environment in which to speak up without fear of reprisal or victimisation from the Company.

Certified Practitioners and or their employees who raise their concerns in good faith when they have genuine suspicions of wrongdoing will be taken seriously and will not be victimised by the Company.

Each Certified Practitioner shall receive a copy of this Code of Conduct.  The Certified Practitioner   shall monitor compliance to this code with their employees and implement special training and/or additional monitoring as appropriate.