The Orchard Pharmaceuticals Company , Inc Code of Ethics requires employees' compliance with all laws and mandates fair dealing in all instances. Violations of our Code of Ethics by employees are not tolerated and can lead to disciplinary action, Inc luding termination of employment and referral for criminal prosecution. As part of our commitment to ensure our products are free from violations of all types of ethical standards, we plan to update our Code of Ethics and employee training materials to include provisions specifically targeted to address human slavery and trafficking.
We condemn the use of forced labor and human trafficking and endeavor to select suppliers who share our ethical standards.
Our manufacturers of intermediate products affirmatively state in their agreements with us that they will comply with applicable laws, which would include laws that prohibit human slavery and trafficking. Similarly, our direct suppliers also state in their agreements with us that they will manufacture product in accordance with Good Manufacturing Practice and in compliance with applicable local laws, which includes prohibitions on human slavery and trafficking.
Although our suppliers are generally not audited by an independent auditor without notice, we conduct audits of our suppliers, yearly or more frequently if necessary, to ensure continued compliance and accountability. These audits, along with the personal engagement of Orchard Pharmaceuticals Company , Inc management and in-person meetings that are routine to the operation of our business with our partners and suppliers, allow us to every extent possible to identify, address and eradicate any violations of laws or our Code of Ethics wherever they could occur in the supply chain.
Suppliers found to use forced labor or human trafficking would be terminated from the Orchard Pharmaceuticals Company , Inc supply chain.
We routinely evaluate and address the risk of ethical violations for all countries involved in our supply chain. We do not routinely engage a third party to conduct this evaluation. Rather, we rely on official government information to identify risks and act accordingly. Our product ingredients are sourced primarily from countries the Spanish Government has designated as being compliant with the Trafficking Victims Protection Act's (TVPA) minimum standards. We take extra precautions before sourcing product from countries that are still making efforts to bring themselves into full compliance with the TVPA. For example, in those countries, we source only from businesses that are affiliated with countries fully compliant with TVPA, visit our suppliers along with their intermediates and vendors in person and only select suppliers that have been in business long enough to verify that their conduct meets ORCHARD PHARMACEUTICALS'S ethical standards.