Code of Business Ethics

Beaufort is committed to the highest standards of ethical business conduct. This code of business ethics provides the standards that Beaufort’s management applies to all employees and others who perform work for Beaufort and its clients. In essence, it requires each of us to conduct the company’s business with good judgment and integrity, in compliance with applicable laws and in a manner that excludes consideration of personal advantage. We share responsibility to apply these principles in every decision we make affecting the company, our colleagues, our clients and ourselves.

Valuable and Actionable Regulatory Compliance Solutions

Our clients engage us to provide valuable, actionable and reliable regulatory compliance solutions. This requires all of us — including those working on a project, project managers and members of the relationship management team — to perform our work thoroughly, accurately and objectively. It requires us to consider all relevant information and to respond thoughtfully and in an unbiased manner when expressing our opinions. And, it requires us to be straight-forward and timely in all communications among ourselves and with our clients — particularly when it appears that our conclusions might include unwelcome news or when we believe that we have identified significant, potential risks to our client, its employees, its business or its customers.

In this regard, all who are working on a project must ensure that their project managers and, through them, the members of our client relationship management team are aware of all significant project developments. This is imperative because the project managers and members of the relationship management team are the only people who are authorized to articulate Beaufort’s official opinions and conclusions regarding a project.

Protection of Client and Third-party Information and Intellectual Property

Beaufort’s employees and associates act appropriately to protect copyrighted or licensed information as well as any confidential or otherwise protected information of our clients and other third parties. In particular, this includes understanding and abiding by any applicable contractual restrictions that Beaufort has agreed to follow with a client or other third party.

We do not discuss, disclose, copy or otherwise use any copyrighted, licensed or confidential client or third-party information without proper authorization from the owner and then only as authorized and required in our duties. We do not use any such client or third-party information for personal gain or advantage for ourselves or another third party. And, we are each responsible for taking appropriate precautions to make sure unauthorized individuals do not have access to or use such information.

Protection of Beaufort’s Information, as well as Intellectual and Other Property

Beaufort’s staff and associates protect and help develop Beaufort’s intellectual property. In keeping with that philosophy, Beaufort endeavors to protect to the greatest extent permissible, in engagement contracts or otherwise, its trade secrets and other intellectual property rights. All work-product of Beaufort’s staff created during their employment with the company and relating to the company’s present or future business is the exclusive property of Beaufort. And, all of us are expected to help identify and secure protection for these innovations. Furthermore, obligations with respect to Beaufort’s confidential and proprietary information continue to apply even after a person’s association with the company ends.

Staff and associates protect equipment and other assets of Beaufort from theft or use by unauthorized persons. Furthermore, to the fullest extent practical, we maintain control over equipment and exercise appropriate safety and security precautions to protect it and its contents from unauthorized access.

Upon leaving the company, employees refrain from erasing any computer data, since to do so would constitute the destruction of company property. Rather, all computer files, emails and paperwork are left “as is” so that another employee may pick up where the departing employee left off.

Similarly, we uphold any applicable contractual, confidential or fiduciary obligations and notify the company immediately if we believe any job activity may conflict with such obligations. Potential employees and contractors resolve any such impediments to their employment and/or other association with Beaufort before accepting employment or a contractual relationship with Beaufort.

Accurate Invoicing

Those who are responsible for recording the time and expenses devoted to client projects, preparing time and expense reports, or creating client invoices use the utmost care to ensure that every Beaufort invoice is accurate, based on complete information and in compliance with the underlying contractual arrangements.

Fair Dealing

Each of us deals fairly and objectively with the company’s clients and their employees, suppliers and competitors. We avoid taking unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other intentional unfair-dealing practice.

The staffing and personnel decisions made by our clients are the sole responsibility of our clients’ managements and typically reflect considerations that are beyond the scope of either our engagement or our knowledge. Because it would be unfair, we avoid becoming involved in our clients’ personnel matters or openly expressing our opinions regarding specific individuals within a client’s organization. If we believe that an unresolved client personnel issue is putting the client or Beaufort at risk, we discuss the matter privately with the appropriate Beaufort project manager or client relationship manager.

Honesty, Integrity and Courtesy

Honesty and integrity are fundamental to the ethical conduct of business. We do not engage in any fraudulent or deceptive activity toward Beaufort, our clients, fellow employees, contractors, or any government agency or official. No such activity is condoned or permitted.

Courtesy and professionalism are an integral part of our service. Each of us treats all people, regardless of their position, with dignity, civility and courtesy. This applies in all business contexts, whether dealing with our customers, fellow employees, associates, regulatory officials or others.

Conflicts of Interest

Employees and associates avoid situations in which a conflict of interest may arise. We also avoid the appearance of a conflict between personal interests and the interests of the company or any of its clients.

Gifts and Business Courtesies

It is a common and accepted business practice to exchange customary gifts and business courtesies in the course of business relations with anyone with whom Beaufort does or may potentially do business. In a commercial setting, the purpose of business courtesies or gifts is to create good will and promote sound working business relationships.

Employees may give or receive customary gifts or business courtesies consistent with the guidelines set forth below. However, it is the employee’s responsibility to exercise good judgment and to act with moderation.

  • Gifts: Gifts accepted from or given to anyone with whom the company does business are only promotional in nature and nominal in value. Gifts of nominal value are unlikely to be perceived as influencing the recipient. Cash gifts are never accepted from or offered to anyone. Beaufort’s employees, consultants or agents do not offer, give, ask for or receive anything of value in exchange for an agreement to purchase or to recommend the purchase of any medical device, pharmaceutical product or medical service.
  • Business Courtesies: Business courtesies include, but are not limited to, meals, drinks, entertainment, recreation, transportation, honoraria or the use of donor’s time, equipment, materials or facilities.

Employees and associates accept business courtesies if doing so is appropriate (that is, the event promotes a legitimate business purpose); reasonable (the invitation is for a meal, entertainment or travel that is not lavish); and consistent with the ethical practices of the company (the employee would not be uncomfortable discussing it with his or her manager or co-workers).

A business courtesy is not to be accepted if it does not fall within these guidelines or if the donor expects something in return, may be attempting to gain an unfair advantage, may be attempting to influence the employee’s judgment or if acceptance creates the appearance of any of the foregoing.

Employees also avoid a pattern of accepting frequent gifts or business courtesies from the same persons or companies.

Health Care Laws and Regulations

Most of our services are subject to various laws and regulations governing the development, manufacturing and marketing of medical devices, in vitro diagnostic devices and pharmaceutical products. We are familiar with the laws, regulations and internationally recognized standards of quality and ethics that apply to our specific areas of practice and responsibility, including the Declaration of Helsinki and the standards of good laboratory (GLP), clinical (GCP) and manufacturing (GMP) practice as well as Beaufort’s Standard Operating Procedures (SOP). We are committed to the unbiased interpretation of these laws, regulations and standards. And, we avoid claims of competence in any area in which we do not have a thorough understanding.

Inside Information and Federal Securities Laws

We comply with applicable law and Beaufort’s code of business ethics and do not trade or tell others to trade in the securities of any company based on confidential information that we learn about a company or any of its products through our work at Beaufort.

Notification Responsibility

It is our collective responsibility to maintain a culture and environment where our code of business ethics is incorporated into every aspect of our business operations. We promptly report any violation of this code of business ethics to the company’s chairman and CEO, or one or more other members of the company’s senior management, for investigation, review and resolution.