Conferre Code of Ethics


This Code of Ethics applies to all CONFERRE SA operators and therefore to the directors, to managers, employees, suppliers, commercial partners and all those who, either on a stable or temporary basis, act on behalf of the Company (hereinafter, the "Recipients").

All Recipients working on behalf of Conferre SA are required to comply with the principles and rules of behaviour foreseen by this Code of Ethics, with the policies and procedures and with all the directives issued by the Company in compliance with and in application of said Code, carrying out their tasks with a high level of commitment, great availability and sense of responsibility for the roles assigned them.

To that end, the Company agrees to implement specific procedures, regulations or instructions aimed at ensuring that the values affirmed here are mirrored in individual behavior, if necessary providing specific contractual clauses and obligations for the Recipients, as well as adequate punishment systems for any violations of the Code itself.

In case of doubt or the need for further clarification regarding full compliance with and interpretation of the contents of the Code of Ethics, the Recipients may contact the (


Art. 1 - Value of good reputation - Building Trust

For Conferre SA reputation plays a central role, in all of its fields of action and services. It aims to Internally, implement decisions that can build the brand identity, improve the customer experience, listen to feedback and have a public relations team.

Art. 2 - Honesty and respect for the law

Within the scope of their professional activity, CONFERRE SA employees are required to diligently comply with the applicable laws, the Code of Ethics and the internal regulations. Under no circumstances may the pursuit of CONFERRE’ s interest justify dishonest conduct.

Art. 3 - Conflicts of interest

In the conduct of any activity, situations where the persons involved in the transactions are, or may even just appear to be, in conflict of interest must always be avoided. This includes both cases where an employee pursues an interest that differs from the company’s mission and the balancing of stakeholders’ interests or takes ‘personal’ advantage of the company’s business opportunities, and cases where representatives of customers or suppliers, or public institutions, act in conflict with the fiduciary duties associated with their position.

As a non-limiting example, the following situations are considered to give rise to conflicts of interest:

• holding top management positions (managing director, board member, head of function) or having interests or contractual, economic or financial relations with suppliers, customers, competitors or commercial partners of CONFERRE SA;
• use of the position within the Company and the information acquired in that position to create conflicts between personal interests and the interests of CONFERRE;
• accepting or offering money, favours or assets to persons or companies that are or intend to be in business with CONFERRE;
• covering public roles with bodies that may have relations with CONFERRE, in such a way as to create the conditions for a potential conflict of interest.

Recipients are required to:

• respect the laws, the internal company rules or the contractual requirements in all of their personal and business relations;
• avoid actions or relations that might be or appear to be in contrast with the obligations taken on by them with respect to CONFERRE, or with the interests of the latter;

Art. 4. – Relation with competitors

CONFERRE SA undertakes to observe the national competition rules in force in the areas where it operates, and none of its employees or collaborators may engage in behaviour or initiatives aimed at unfairly affecting the market.

Art. 5 - Accuracy in the execution of tasks and contracts

Contracts and work assignments must be performed as responsibly agreed upon by the parties. CONFERRE SA undertakes not to take advantage of conditions of unforeseen events or weaknesses of its counterparts. In existing relationships, efforts must be made to ensure that anyone acting in the name and on behalf of CONFERRE SA attempts to take advantage of contractual shortcomings, or unforeseen events to renegotiate the contract for the sole purpose of exploiting the position of dependence or weakness in which the counterparty has found itself.

Art. 6 - Value of human resources

The Company's employees and associates represent a fundamental asset for the success of CONFERRE SA.

CONFERRE protects and promotes the value of its human resources with the aim of improving and increasing their skills. The Company contributes to the training and professional growth of its employees and collaborators by ensuring each worker learns about their colleagues’ respective work experiences and through other training measures that enhance their own professionalism.

Art. 7 - Protection of personal integrity

CONFERRE SA ensures working conditions which respect individual dignity and a safe and healthy working environment; more specifically CONFERRE SA undertakes to:

• prevent any form of health risk or hazard;
• provide workers with the necessary means and information to prevent all types of risk

Art. 8 - Impartiality

CONFERRE SA avoids any form of discrimination based on the age, sex, sexual orientation, state of health, race, nationality, political opinions and religious beliefs of those with whom it deals.

Art. 9 - Confidentiality and handling of data and information

CONFERRE SA guarantees the confidentiality of the information that may come into its possession for whatever reason and refrains from seeking confidential data, except in the case of express and conscious authorisation and in accordance with the legal regulations in force.

In addition to this, the Recipients are obliged not to use confidential information for purposes other than to carry out their professional business and duties.


Art. 10 – Relations with Customers

CONFERRE SA bases its activities on the criterion of quality, essentially understood as the objective of full customer satisfaction, in full compliance with applicable rules and regulations in the markets on which it operates.

CONFERRE SA is committed to ensuring that courtesy, fairness, attention, good practice and clarity of communication and commercial negotiations are distinguishing elements in its relations with customers.

All offers will be formulated in a way that ensures compliance with adequate quality standards and safety measures, as well as appropriate salary levels for employees

Company operators must not offer any gifts or other asset that may create embarrassment, condition choices or raise doubts that their behaviour is not transparent or impartial.

In the conduct of any negotiations, situations in which the persons involved in the transactions are or may appear to be in conflict of interest must always be avoided.

Art. 11 – Relations with Suppliers

CONFERRE SA aims to provision itself with products, materials, works and services at the most advantageous conditions in terms of quality/price ratio. However, this aim must be combined with the need to implement supplier relations that ensure operating methods compatible with both human rights requirements and those of workers and the environment. For that purpose, with respect to suppliers, CONFERRE SA has a commitment to act in a way that respects human rights, workers' rights and the environment.

CONFERR SA uses suppliers, consultants and partners who operate in accordance with the regulations in force and the rules set out in this Code

CONFERRE SA will carry out periodic assessment of its suppliers in terms of verifying their economy and efficiency. Consequently, any potential supplier with the necessary requirements, shall not be denied the ability to compete and offer its products/services.

Art. 12 – Event organisation and relations with health professionals

All the events, educational events, congresses and conferences, whether national or international, of a scientific or professional medical nature are organised by the Company, either directly or indirectly, under the instructions of national bodies, organizations, institutions, academies and universities, by university hospitals and hospital trusts within their sector, by federations of medical associations and/or by pharmaceutical companies of national or international level.

These events must be of a strictly technical-scientific nature and must be organised based on ethical, scientific and economic criteria, with prior definition of a qualified technical-scientific plan, in full compliance with the laws that may be applicable at the time, as well as:

- the regulations on the transparency of money transfers between pharmaceutical industries, health care professionals (HCPs) and health care organisations (HCOs), including the code on the transparency of financial transactions between the pharmaceutical industry, doctors and medical organisations according to the Code of conduct of the National Organization of Medicine and the Hellenic Association of Pharmaceutical Companies (SFEE)
- the code of practice, for example regarding the location and duration of the events, recipients and participants, speakers, side events, hospitality of accompanying third parties of whatever level and in whatever form
- the code of ethics of other healthcare industry Associations
- the applicable CME rules and regulations in force.

With particular reference to the relations and interactions with doctors and health care professionals (HCPs), who are taking part in the events or are speaking at them, and in effecting those relations (for example in terms of hospitality), CONFERRE SA ensures the compliance with laws, regulations and standards of behaviour applicable to the pharmaceutical sector, including those relating to the fight against corruption and the prevention of money-laundering, together with respect for any contractual obligations that may have been taken on with the pharmaceutical companies sponsoring the events.


Art. 13 - Ethical commitment of the Corporate Bodies

Proper and effective application of this Code of Ethics is only possible with the commitment and help of the entire CONFERRE structure. As a result, every one of the Company's management and/or control bodies must make its individual actions in line with the ethical principles of the Code of Ethics and must co-operate with the bodies that are more directly and operationally responsible for its implementation and control process.

Art. 14 - Responsibility of corporate bodies

Corporate bodies, and in particular the management, are also committed to promoting sharing and respect of the Code of Ethics, acting with the greatest professionalism and sense of responsibility, in the awareness of their top role and their position of leadership and reference for proper application of the Code itself for those who more generally work on behalf and in the interests of the Company.

Art. 15 - Communication and Training

The Code of Ethics is brought to the attention of internal and external stakeholders through appropriate communication activities. These activities form an integral part of the institutional plan for internal and external communication set up by the respective corporate functions responsible, and they are activated at the time of initial release of the Code of Ethics and on all subsequent revisions thereof.

To encourage proper understanding of the Code of Ethics by CONFERRE SA employees and associates, the Managing Director, also with the assistance of other internal corporate functions or external consultants, draws up and delivers a training plan aimed at encouraging knowledge of the ethical principles and rules of behaviour.

All employees and associates are given a copy of this Code of Ethics.

Art. 16 - Internal control, violation of the Code of Ethics and notifications

Compliance with the rules and principles of the Code must be considered an essential part of all the Company's working or commercial relations.

CONFERRRE SA adopts specific procedures to monitor the conformity of the conduct of anyone who acts for the company or within its sphere with the provisions of the regulations in force and the rules of conduct of this Code.

More specifically, the Recipients must consider compliance with the provisions of the Code as an essential part of their contractual obligations.

Violation of the principles in the Code of Ethics (like those defined in the Model and/or in the internal procedures) compromises the fiduciary relation between the Company and its management, employees, consultants, associates of whatever kind, customers, suppliers and commercial partners, and represents a failure to fulfil the obligations taken on by these latter, with all legal consequences.

If a violation of the Code of Ethics is ascertained, this will result in sanctions, issued to protect corporate interests and in line with applicable regulations, internal procedures, which may also lead to termination of contract or the preclusion of further relations, either on a temporary or a permanent basis, along with requests for compensation to cover any damage sustained.

Any violation or suspected violation of the Code of Ethics may be notified by the parties involved, even anonymously, provided they give a detailed description sufficient to allow reconstruction and verification of the facts, (

APPROVED IOANNINA, 06/11/2023 The Director