About Medpace, Inc.
Our unique partnering philosophy emphasizes our uncompromising commitment to clinical research and to the highest level of ethical standards and performance in our jobs. We are selective about the number of projects we engage in because we are devoted to quality and providing our partners with best in class service. Medpace’s dedicated teams serve as an extension of your team – we engage quickly and provide strategic thinking – ensuring quicker start-up times, superior quality, and the most efficient delivery of every phase of trial. Our therapeutic and regulatory experts are determined to streamline your path to approval so every partnership is designed to create research solutions focused on your critical needs.
Code of Business Conduct and Ethics
All Medpace employees, officers, and directors are held to the highest standards of ethical behavior in all business dealings and must fully comply with all applicable laws and with the Code of Business Conduct and Ethics (“Code”). Please visit the Investors section to review the Code.
Honesty, confidentiality, integrity, and adherence to Medpace policies, standard operating procedures (SOPs) and applicable regulatory guidelines are our governing principles. All are held accountable for their actions and are required to report unethical or unlawful activities as well as any violations of this Code. Anyone who violates this Code is subject to disciplinary action, which may include termination of employment and/or legal action.
- The CEO, CFO, Compliance Officer, and all other members of the Medpace management team are responsible for working within their respective areas of responsibility to ensure that the Company operates in compliance with all applicable laws, rules, and regulations that govern the conduct of the company’s business worldwide. They are also responsible for promoting honest and ethical conduct including recognizing actual or potential conflicts of interest amongst themselves and others and for taking appropriate action to prevent collusion and inappropriate or unlawful financial transactions.
- All employees, officers, and directors will work to ensure that financial information and all other public communications are reported completely, honestly, accurately, timely, and in an understandable manner.
- All employees, officers, and directors are responsible for understanding and complying with all applicable company policies and SOPs.
- Open communication is encouraged throughout the organization.
- Confidential information should be disclosed only when authorized or required.
- Any violation of the Code or applicable law must be reported to the Corporate Compliance Officer or the Audit Committee of the Board of Directors.
Compliance with Anti-Bribery and Corruption Laws
The Foreign Corrupt Practices Act (“FCPA”) is a United States federal law that applies to Medpace and its international subsidiaries. The UK Anti-Bribery Act also applies to Medpace and its subsidiaries. All Medpace companies around the world potentially fall within the scope of these laws.
- The FCPA and the UK Anti-Bribery Act prohibit companies or individuals from directly or indirectly making payments or offering anything of value to government officials or private individuals for the purpose of influencing any official act or decision, or encouraging or discouraging any action in violation of any legal duty, to secure an improper business advantage.
- Medpace is committed to full compliance with the FCPA and the UK Anti-Bribery Act. Medpace strictly prohibits making any payments or providing gifts or anything of value to a government official or private individual to influence an official act or decision or to induce the person to do or not do anything in violation of the person’s legal duty, in order to gain a business advantage. This includes any payments, gifts or favors, using Medpace funds or personal funds, by any Medpace employee, or by any third party on behalf of Medpace or a Medpace employee.
- Government official includes anyone who is an officer, employee or representative of a government of any country, or a state-owned entity including, for example, government-owned or controlled hospitals or physicians, or members of agencies or committees performing government functions such as granting, withholding or withdrawing regulatory approvals, licenses and permits.
- In order to ensure compliance with the law, it is essential that Medpace financial records accurately and fairly reflect all corporate transactions, no matter how small. Recording any payments, gifts or other expenditures in any way that would conceal their true nature, the recipient, or the amount is also a violation of this policy. No undisclosed or unrecorded funds or assets of Medpace are to be established for any purpose.
- The Medpace Corporate Compliance Officer, acting on behalf of and under the authority of the company’s Board of Directors, is responsible for the enforcement of this policy. The Corporate Compliance Officer works with management to develop, implement, maintain and monitor appropriate policies and procedures which support compliance, inform Medpace employees and contractors of their specific responsibilities under this policy, monitor for compliance, and address any non-compliance. The Corporate Compliance Officer periodically reports on these efforts to the Board of Directors.
- Violation of the law on which this policy is based can subject Medpace and its Board of Directors, management and employees to prosecution, criminal fines and imprisonment.
UK Modern Slavery Act
Medpace is fully committed to complying with all applicable laws, including the UK Modern Slavery Act
Reporting Actual or Suspected Violations
- All reports of actual or suspected violations of the Code or the FCPA and the UK Anti-Bribery Act must be made to the Corporate Compliance Officer or the Chair of the Audit Committee of the Board of Directors immediately upon discovery.
- The Corporate Compliance Officer or the representative of the Audit Committee may be notified in person, via US mail, telephone or email.
- From inside the US: Medpace phone number: 513-579-9911 x 12898; or toll free long distance within the US: 877-394-3528.
- From outside the US: From inside Medpace international offices, dial extension 12898; or to make a toll free call from outside Medpace offices, using the link below, call the phone number listed next to your country name, then enter extension 12898 when the directory prompts you for an extension number.
- Medpace has also established an Ethics Hotline through NASDAQ that is available 24 hours a day, 7 days a week at (844) 421-1611. An employee, officer or director may remain anonymous and will not be required to reveal his or her identity in calls to the Ethics Hotline, although providing your identity may assist the Company in addressing your questions or concerns. For more information, please visit the Investors section.
- Medpace Toll-Free Numbers
- All employees are held accountable for their actions and are required to report unethical or unlawful activities, violations of the Code, or violations of the Policy on Anti-Bribery and Corruption to the Corporate Compliance Officer. Managers are ultimately responsible for ensuring that the employees they supervise are knowledgeable about and in compliance with all Medpace policies. Any employee who violates the Code or the Policy on Anti-Bribery and Corruption, or who is aware of, but fails to report any such violation or any other unlawful or unethical business behavior, is subject to disciplinary action, including termination of employment and/or legal action.
- Reasonable judgment must be exercised to avoid baseless allegations. An employee who intentionally files a false report of wrongdoing will be subject to discipline up to and including termination. Employees who file reports in good faith will not be subject to discipline.
- Retaliation for filing a report is prohibited. Any employee who has reported what he/she believes to be illegal or unethical activity or a violation of the Code and who believes he/she is being retaliated against must contact the Corporate Compliance Officer immediately. The right of an employee for protection against retaliation does not include immunity for any personal wrongdoing that is alleged or discovered in the course of the investigation.
- Anonymous reports will be accepted, but those making a report are encouraged to identify themselves in case more information is needed during the investigation. To the extent possible, the confidentiality of the person filing the report will be maintained. However, identity may have to be disclosed to conduct a thorough investigation, to comply with the law and to provide accused individuals their legal rights of defense.
- A person making a report is not responsible for investigating the activity or for determining fault or corrective measures. Appropriate management officials are charged with these responsibilities.
Vendor Code of Conduct
The mission of Medpace, Inc., and its global affiliates (“Medpace”) is to accelerate the global development of safe and effective medical therapeutics. Pursuant to this mission, Medpace conducts clinical trials on behalf of Sponsors. As a Clinical Research Organization (CRO) Medpace is a critical link connecting lifesaving innovations in medicine and medical devices with the communities of patients who depend on them. Medpace is committed to engaging with its stakeholders (employees, customers, and vendors) to uphold the highest legal and ethical standards while maximizing value to shareholders. As a publicly traded company, Medpace acknowledges the importance of transparency, and is dedicated to ensuring that all aspects of its operations are subject to evaluation and scrutiny in line with its mission and values. This Vendor Code of Conduct contains general guidelines to encourage the highest standards of ethical conduct by vendors who perform services for or on behalf of Medpace. All vendors are expected to review and understand this Code of Conduct.
Vendors shall perform services in compliance with all applicable laws and regulations, including industry standards, and licensing requirements.
In carrying out responsibilities, neither a Vendor, nor any of its representatives, affiliates, or subcontractors will make any payments or provide gifts or anything of value to a government official or private individual to influence an official act or decision, or to induce the person to do or not do anything in violation of the person’s legal duty, in order to gain a business advantage.
Vendors are expected to adhere to all applicable laws related to prohibited imports, exports, or financial transactions of any kind. United States economic sanctions regulations prohibit U.S. persons, including financial institutions and their foreign branches and non-U.S. affiliates, from exporting financial services to certain foreign governments and their specially designated nationals named by the Office of Foreign Assets Control (“OFAC”). All vendors should be aware of applicable sanctions and boycott laws, and implement procedures to ensure compliance.
Medpace is opposed to child labor, forced labor, and all forms of modern slavery, and committed to preventing it within Medpace. Medpace demands the same attitude of all who work for Medpace and expects it of all parties with whom we have business dealings. Vendor affirms its compliance with all applicable laws, statutes, and regulations relating to forced labor, child labor, and all forms of modern slavery in any jurisdiction in which it does business. Vendor has and will maintain in place its own policies and procedures to ensure compliance with such laws and regulations and will expect it of all its subcontractors and vendors in its supply chain.
Medpace recognizes that respecting the personal data of individuals is an essential component of its business. Therefore, Medpace is committed to protecting the privacy of individuals of all nationalities in the processing of their personal data, recognizing the fundamental rights to lawfulness, fairness, and transparency. Medpace expects its vendors to adhere to all applicable data privacy laws, and to abide by the essential tenants of lawfulness, fairness, and transparency; purpose limitation; data minimization; accuracy; storage limitation; integrity and confidentiality (security); and accountability.
Corporate Compliance Officer
Stephen Ewald, JD
General Counsel & Corporate Secretary
Medpace Corporate Headquarters
5375 Medpace Way
Cincinnati, Ohio 45227, USA
Tel: +1.513.579.9911, ext. 12055