Ethics & Compliance

Thera Health Policy & Access: Code of Business Ethics & Professional Conduct

(June 2026)

1. Purpose and Scope

Thera Health Policy & Access (“Thera”) is committed to the highest standards of integrity, transparency, and ethical conduct. This Code applies to all employees, consultants, advisors, and third-party partners (“Partners”) engaged with Thera. Adherence to this Code is a mandatory condition of our professional relationship.

2. Ethical Standards and Patient-Centricity

In alignment with the IFPMA Code and APEC principles, we prioritize the interests of patients above all else.

All interactions must be guided by the principle that healthcare decisions are based on clinical evidence and patient needs.
We reject any form of inducement or unethical influence that could compromise professional medical judgment.

3. Transfers of Value (ToV) and Transparency

Transparency is the cornerstone of our operations. Any transfer of value between Thera (or its Partners) and Healthcare Professionals (HCPs) or Healthcare Organizations (HCOs) must be:

Legitimate: Based on a clear, documented service agreement with fair market value compensation for actual services rendered.
Transparent: Fully disclosed in accordance with local, regional, and international transparency reporting requirements.
Non-Promotional: Never used as an incentive to prescribe, recommend, or purchase medical products.

4. Competition Law and Antitrust Compliance

Thera operates in full compliance with global antitrust and competition laws, adhering to recommendations from the International Competition Network (ICN) and standard trade association guidelines.

A. Core Antitrust Principles

Independent Decision Making: All Partners shall conduct their business independently. Agreements or informal understandings to fix prices, allocate markets, rig bids, or limit production are strictly prohibited.
Information Exchange: We prohibit the exchange of commercially sensitive information (e.g., current/future pricing, strategic business plans, or non-public customer lists) with competitors.

B. Multi-Stakeholder Collaboration & Consortia

As a convergence platform orchestrating collaborative projects, Thera mandates strict adherence to these safeguards:

Pre-Competitive Boundary: Collaboration is permitted only for legitimate, pro-competitive objectives, such as improving regulatory frameworks, standardizing data, or enhancing patient access.
The “Firewall” Protocol: Thera acts as a neutral aggregator. Competitors must provide data to Thera independently; Thera will aggregate or anonymize data before group presentation to prevent sensitive information exchange.
Prohibited Discussion: Consortium meetings are strictly limited to the pre-competitive agenda. Discussions regarding pricing, product margins, or specific commercial strategies are forbidden.
Documentation: All meetings must have a pre-circulated agenda and formal minutes. “Sidebar” discussions between competitors during Thera-orchestrated events are prohibited.

5. Third-Party Due Diligence and Compliance

Due Diligence: We conduct thorough vetting of all Partners to ensure their commitment to ethical business practices.
Monitoring: Partners are required to notify Thera immediately of any potential conflict of interest or breach of this Code.
Zero Tolerance: Thera maintains a zero-tolerance policy regarding bribery, corruption, and collusion, in strict compliance with the UN Convention Against Corruption and local anti-bribery legislation.

6. Commitment to Continuous Improvement

Thera encourages an “open-door” policy for reporting ethical concerns. All reports will be handled with confidentiality, and non-retaliation for good-faith reporting is guaranteed.

Acknowledgment: By engaging in services for Thera Health Policy & Access, you certify that you have read, understood, and agree to abide by the principles set forth in this Code. Compliance is a condition of participation in any Thera-led project or consortium.