KNIGHT’S COMPLIANCE CULTURE
Knight Therapeutics is a pan-American (ex-US) specialty pharmaceutical company dedicated to providing life changing,
innovative and affordable medicines for patients in Latin America and Canada through the acquisition, in licensing,
out-licensing, marketing, and commercialization of innovative prescription pharmaceuticals and branded generics in
these markets.
Knight is committed to conducting business in all of its territories in accordance with applicable laws and
regulations. To help ensure compliance, Knight has established and maintains an effective Compliance Program that
is based on company values and consists of various elements designed to help all employees avoid violating laws,
regulations or the company policies and procedures and promotes a strong ethical culture within the organization. In
the event Knight becomes aware of violations of law or company policies and procedures, the company will investigate
the matter and, where necessary, take disciplinary action and implement corrective measures to prevent future
violations.
Knight leaders play a fundamental role in disseminating the Program's guidelines to their respective teams, acting in
an exemplary manner and encouraging open dialogue with employees so that they feel comfortable reporting any concerns
of violations of these policies and procedures.
The fundamental elements of Knight’s Compliance Program are described below and are dynamic and continuously reviewed
to ensure adjustments or refinements when necessary.
KNIGHT’S COMPLIANCE PROGRAM
Knight has established written compliance policies, procedures, and practices that guide the behavior of its
employees in day-to-day operations.
The Code of Ethics and Business Conduct is just one part of the overall program to assure that employees worldwide
follow the appropriate standards and comply with all legal requirements that affect the manner in which Knight
operates, including pharmaceutical industry guidelines, laws, regulations, and guidance in each country where Knight
does business. In addition to the Code of Ethics and Business Conduct, other policies have been developed and
implemented that outline the company’s commitment to compliance and corporate responsibility. Knight communicates
policies and procedures via live training activities and the company’s intranet.
Knight is committed to ensuring that the Compliance Officer has the ability to implement change within the company as
necessary and to exercise independent judgment.
The Compliance Department works closely with and seeks the advice and counsel of the Compliance Committees with
regards to implementation and changes to the Compliance Program.
The Compliance Committee is made up of senior-level leaders at Knight with the purpose of identifying, evaluating and
mitigating risks that may arise linked to the execution of Knight's processes, especially related to interactions with
healthcare professionals and other stakeholders. The Compliance Committee promotes ethical behavior and awareness of
Knight’s policies and procedures to further reinforce accountability and ensure continuous improvement of such
processes.
A critical component of the Compliance Program and creating an ethical culture at Knight is to train and communicate
to employees in a transparent and honest way regarding legal and ethical obligations under applicable laws, rules,
regulations, industry codes, and company policies and procedures. It is important that everyone understands their role
in ensuring the success of Knight’s Compliance Program.
Knight has implemented training programs to educate employees on the Code of Ethics and Business Conduct, on new and
existing compliance policies and on the standards and procedures applicable to their job functions. The training
materials cover the laws and regulations that affect the way Knight conducts business and is customized to meet
specific regional requirements.
New employees receive compliance training as part of their onboarding and all employees receive ongoing compliance
trainings on an annual basis. Knight implements additional training for the entire company or departments and/or
business units on an as-needed basis.
Knight is committed to fostering dialogue between management and employees about reporting concerns or questions
about non-compliance.
All Knight employees have a responsibility to report misconduct (either suspected or confirmed) and are encouraged to
discuss these questions or concerns with their line managers, Human Resources department, Compliance department or
other members of the management team.
Knight’s employees may also report non-compliance through Knight’s Ethics Hotline, a global confidential
communication channel available in multiple languages, 24 hours a day, 365 days a year through which employees,
suppliers, customers and other interested parties can report misconduct (either suspected or confirmed) or situations
that are contrary to Knight's Code of Business Conduct and Ethics.
The Ethics Hotline is operated independently by the Compliance Department, which directly receives all reports for
analysis using a system that guarantees strict confidentiality standards.
Knight adopts all the necessary measures to ensure the confidentiality of the information received and the fair
treatment of whoever is allegedly involved in the reported facts, respecting their right to defense. Likewise, the
presumption of innocence is guaranteed to all affected persons. Knight will not tolerate any type of punishment or
retaliation against people who, in good faith, report possible violations of the Code of Business Conduct and Ethics.
To ensure conformity with the Compliance Program, it is necessary to implement, improve and maintain a constant
evaluation process which aims to identify whether the pillars of the Program are being adhered to.
Internal monitoring and auditing are integral parts of Knight’s comprehensive Compliance Program. Effective
monitoring and auditing can detect and prevent deviations that can potentially prompt compliance concerns. Knight’s
Compliance and Internal Audit functions conduct a variety of monitoring activities in an effort to detect and
respond to potential issues of non-compliance. The compliance monitoring and auditing program is modified as necessary
in response to new regulatory requirements, changes in business practices, and other considerations.
Knight’s Code of Ethics and Business Conduct and company policies educate employees about Knight’s commitment to
compliance. It is the responsibility of every employee to read, understand and follow these guidance materials.
Failure to comply with Knight’s established policies, procedures, and the overall Compliance Program will be treated
as a breach of company policy and will result in appropriate disciplinary action, up to and including termination for
Knight’s employees. Although each situation is considered on a case-by-case basis, the company will consistently
undertake appropriate disciplinary action to address non-compliance and deter future violations.
Knight’s Compliance Program supports prompt response and corrective action for detected problems as appropriate
under the circumstances. Regardless of how a potential compliance concern is raised, it will be carefully reviewed,
investigated in a timely manner and appropriately resolved.