OUR COMPANY

Code of Conduct

 

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Our Commitment to Corporate Compliance

At Greenwich Biosciences, we are committed to conducting our business in an ethical manner and in compliance with all applicable laws, rules and regulations. We created a principles-based program, I-CARE, around the core elements of Integrity, Compliance, Accountability, Respect and Ethics.

We have developed a code of conduct that embodies our high ethical standards, and we are committed to operating our business, and conducting our relationships with patients, physicians and stockholders, accordingly. We ask and expect that our employees strictly adhere to these standards.

 

Code of Conduct

We continually reinforce our values through our Code of Business Conduct & Ethics. Click here to download a copy.
 

Our primary purpose is to make a positive and meaningful difference in the lives of patients and their caregivers. All of our actions and decisions tie back to this most important and simple fact. Equally, we want our employees to understand and trust that GW Pharmaceuticals and its US subsidiary, Greenwich Biosciences, is committed to doing the right thing. So, we have made it clear what we expect from all of our colleagues.

Justin Gover
Chief Executive Officer

 

In addition to providing guidance on our business standards and practices, our I-CARE approach ensures that all of our actions reflect our commitment.

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Greenwich Biosciences Declaration of Compliance

Dated: August 1, 2020

 

NOTICE: This information is provided pursuant to the requirements of California Health & Safety Code §§119400-119402 (S.B. 1765), which requires certain pharmaceutical and medical device companies doing business in California to make available their program for compliance with applicable federal and state laws and industry standards regulating the marketing and promotion of their products. With specific reference to the provision of gifts, promotional material, or items or activities that a pharmaceutical company may provide to an individual medical or healthcare professional. Greenwich Biosciences has established an annual limit of two thousand five hundred dollars ($2,500) on promotional materials, or items or activities that Greenwich Biosciences may give or otherwise provide to an individual medical or health care professional in California. The dollar limit is a maximum only. Greenwich Biosciences declares that, to the best of our knowledge, and based on our good faith understanding of the statutory requirements of the California Health & Safety Code sections 119400 and 119402, we are in compliance with our comprehensive Compliance Program as of the date below. Copies of this declaration and the Comprehensive Compliance Program may be obtained by calling Greenwich Biosciences’ compliance helpline at 1-800-461-9330 or by email request to i-care@greenwichbiosciences.com. 
 
Date last reviewed: August 1, 2020

 

Our Comprehensive Corporate Compliance Program (“I-CARE Program”)

Greenwich Biosciences is committed to establishing and maintaining an effective Compliance Program. The structure of the Greenwich Biosciences Compliance Program follows the seven compliance program elements outlined in the Office of Inspector General ("OIG") Compliance Program Guidance for Pharmaceutical Manufacturers.

Greenwich Biosciences’ I-CARE Program is outlined below. The program helps to guide us in our day-to-day and long-term activities. We intend to periodically reexamine the program to ensure it is efficient and effective. Accordingly, the Compliance Program may be amended or revised by Greenwich Biosciences from time to time.

  • Guiding Principles 
  • Corporate Compliance Committee 
  • Compliance and Integrity Training 
  • Compliance Monitoring and Auditing 
  • Compliance Investigations and Corrective Disciplinary Actions

1. Guiding Principles

  • Greenwich Biosciences is committed to conducting all business affairs in accordance with the “I-CARE Guiding Principles.” The guiding principles help ensure Greenwich Biosciences and company Representatives adhere to our company values, which will in turn support compliance with external requirements. 

    I-CARE Guiding Principles 
    • Put patients first. 
    • Conduct business fairly and honestly, in compliance with relevant laws, regulations, and industry standards.
    • Innovate responsibly, productively and safely. 
    • Ensure that all interactions with the Healthcare Community are based on a legitimate business need. 
    • Communicate in a fair and balanced manner with external stakeholders. 
    • Promote teamwork and collaboration across all departments and geographies. 


2. Corporate Compliance Committee

In addition to the roles played by our parent company’s Board of Directors, and CEO, Greenwich Biosciences maintains a multi-level compliance structure that includes the following:

  • Global Chief Compliance Officer
  • US & Global Corporate Compliance Committees 
    • Corporate Compliance Committee is a multi-disciplinary committee of managers appointed by the Compliance Officer that is responsible for advising and supporting the Compliance Officer in the implementation and oversight of the compliance program. The Compliance Officer serves as chairperson of the Committee. 


3. Compliance and Integrity Training

Our training program includes, but is not limited to:

  • Requiring ongoing training and education of its Company Representatives on application of Greenwich Biosciences’ Guiding Principles, and individual obligations under applicable legal requirements and internal company policies 
  • Greenwich Biosciences provides training for every Company Representative on Greenwich Biosciences’   I-CARE Program, including Greenwich Biosciences Code of Business Conduct and Ethics and all applicable compliance-related policies, including their content and application to daily activities. The goal of this training is to help orient Company Representatives to Greenwich Biosciences’ Guiding Principles, which shape the I-CARE Program 
  • In addition to the Code of Business Conduct and Ethics and above-referenced compliance-related policies, Greenwich Biosciences also provides targeted training in key functional and risk areas whose job role and responsibilities are affected by those functions and risk areas. 
  • All Company Representatives who may interact with the Healthcare Community will certify initially, as well as on an annual basis, that they have completed trainings and that they received and are complying with Greenwich Biosciences’ I-CARE Program policies and procedures. 

Supplemental training may also be provided to employees based on evolving legal and regulatory requirements.


4. Compliance Monitoring and Auditing

  • I-CARE Program is committed to ongoing efforts to assess, evaluate, monitor and audit compliance in accordance with Greenwich Biosciences’ compliance guiding principles, policies and procedures. Regular Auditing and Monitoring enables Greenwich Biosciences to identify potential process weaknesses and to strengthen controls to guide the business in preventing excessive risk. 
    • If non-compliance and/or improper conduct are discovered during the course of Auditing and Monitoring activities, Greenwich Biosciences will investigate the matter further and, where appropriate, will take corrective and/or disciplinary action. 
    • All Company Representatives, including certain Third Party Vendors, are subject to periodic monitoring and auditing to evaluate adherence to all Greenwich Biosciences’ compliance guidelines, as well as relevant laws, regulations, and industry guidance. 


5. Compliance Investigation and Corrective and Disciplinary Actions

Greenwich Biosciences is dedicated to fostering dialogue between management and Company Representatives. The goals of Greenwich Biosciences’ compliance reporting and investigations process are to ensure adherence to (1) our Guiding Principles, (2) GW’s Code of Business Conduct and Ethics and (3) the letter and spirit of applicable laws, regulations, and industry standards.

  • Greenwich Biosciences’ compliance investigations process is the responsibility of the Compliance Officer, and the process seeks to address and resolve compliance-related issues fairly, quickly, and consistently with the associated goal of preventing further violations. 
  • Greenwich Biosciences strives to maintain an environment that promotes open communication. Greenwich Biosciences upholds an “open door” policy and promotes a “speak-up” culture that fosters trust and allows Company Representatives to report suspected violations. As such, Greenwich Biosciences encourages Company Representatives to speak up when they see or suspect something that could harm individuals that we serve or violates applicable laws, regulations or internal policies. Any retaliation or intimidation will not be tolerated against any Company Representative who makes a good faith report of a suspected violation or who participates in good faith with an investigation of a potential violation (even if the investigation fails to substantiate the report).

We encourage all employees to express their concerns, and we provide several channels for communication:

  • I-CARE Helpline (24x7)
  • Web-based reporting system
  • Open Door Policy
  • Exit interviews

We expect employees, officers and directors to promptly report suspected, planned or actual violations of our directives and guidelines and/or the laws which govern our activities. We encourage reports to be made to a supervisor, manager, or directly to a member of the I-CARE team. If these individuals are not available or if the reporter (including a person from outside the company) prefers, reports of violations may be made on an anonymous basis via Greenwich Biosciences’ I-CARE toll-free Helpline. This helpline is available 24 hours a day, 7 days a week by calling 1-(800)-461-9330. Employees and third parties also have the option to submit reports via a website https://www.convercent.com/report and will be provided with a case number that they can use to track the status of their report.

We also encourage our employees and partners to ask questions about any activity where they are unclear about
a potential violation or application of our I-CARE Program (i-care@greenwichbiosciences.com). Questions may be posed through any of the established channels. Acts of retaliation or retribution against an employee or officer who in good faith reports a potential, suspected, planned or actual violation or application of our directives and guidelines and/or laws are not permitted.

 

California Transparency in Supply Chains Act

Greenwich Biosciences, Inc. and our parent company, GW Pharmaceuticals plc (GWPH) are committed to safe and fair working conditions.  We require all suppliers with whom we contract to agree to uphold the standards of our 3rd Party Code of Conduct, which prohibits engaging in illegal behavior, including human trafficking and slavery.  Product-related suppliers are audited by the Quality Assurance department. Employees and contractors GW’s Code of Conduct and Business Ethics may be subject to reprimand or other adverse consequences, up to and including termination of employment or assignment. As we expand our network of suppliers, the Company is committed to strengthening its internal processes in the following key areas:

  • Vendor assessment & diligence;
  • Vendor audits for trafficking and slavery in its supply chains;
  • Direct supplier certifications;
  • Monitoring vendor compliance;
  • Employee training on human trafficking and slavery.