Ethical Business Logo

What is it?

The “Ethical Business Logo” is a Logo licensed by Eucomed which can be obtained by any company member of Eucomed.

A company that uses the Logo not only commits, as all members of Eucomed, to the Eucomed Code of Ethical Business Practice but has in addition implemented the three following elements:

Establishment and implementation, within its organisation, of written policies and procedures consistent with the provisions of the Eucomed Code;
Identification and appointment of a senior contact person within the company responsible for the compliance with the Eucomed Code and/or the company's written internal policies and procedures transposing the Code internally;
Provision of comprehensive and regular trainings to company employees on the Eucomed Code or the Company policies transposing the Code internally.

The Logo is based on the self-certification by the company CEO or the EMEA President (or equivalent) that his/her company adheres to the high ethical standards embodied by the Eucomed Code of Ethical Business Practice and that it has an effective compliance programme in place.

This Logo is not intended to certify that the company has an effective compliance programme under Foreign Corrupt Practices Act (FCPA) or any other legislation.

What is its value?

The Ethical Business Logo is a visual sign that displays to stakeholders the commitment of the licensed company to the ethical standards embodied by the Eucomed Code of Ethical Business Practice. It is intended to ensure and strengthen public confidence in the integrity of the industry, and effectiveness of member organisations’ compliance programmes, built on the Eucomed Code of Ethics.

Stakeholders will be confident that they are dealing with a company that maintains high ethical business standards and has an effective compliance programme in place.

Concretely, the Logo intends to support companies in:

improving public trust in the MedTech business;
becoming the preferred choice of ethically concerned customers/consumers;
attracting investments from ethically oriented investors;
drawing and retaining highly principled employees and improving employee morale.

Where can it be used?

Any company granted the right to use the Logo may use it on:

print or electronic materials such as annual reports, promotional material, business cards, stationery, and conference banners and signs;
the company’s website(s).

The Logo cannot, however, be used in a manner or associated with text which implies that Eucomed has endorsed or approved any company’s products, technology or individual compliance plans or practices.

Eligibility

All Eucomed members are required, based on the Eucomed governance rules, to commit to acting in compliance with the Eucomed Code of Ethical Business Practice, as amended from time to time. All Eucomed members can request a licence to use the Logo.

However, the right to use the Logo is linked to the additional commitment from the company’s CEO or the EMEA President (or equivalent) that his/her company has transposed internally the three specific obligations set out in the self-certification agreement (i.e. appointment of a compliance officer, establishment of internal policies procedures transposing the Code internally and provision of comprehensive and regular trainings to employees).

Non-member of Eucomed?

During the first year of its introduction, the Ethical Business Logo system is only open to the member companies of Eucomed. As of 1 October 2012, the self-certification system may open up to any medical technology manufacturer, distributor or healthcare related service organisation.

Further information will be published here in due time.

Obtain the Ethical Business Logo

Duly complete the Licence Agreement (to be signed by the company CEO/EMEA President and the company EMEA Compliance Officer), including Appendixes such as the Compliance Questionnaire in Appendix II.

Send the form and supporting documents back to ethics@eucomed.org. Information provided by the company will be reviewed and approved by Eucomed.
Once the application is approved, pay the yearly fee to finalise the process*.

The name of your company and the company Compliance Officer will be published on this page once your application is finalised.

*The licence of the Ethical Business Logo is free of charge until 1 October 2012. Passed that date, the licence to use the Logo will be charged on a yearly basis. The fee will differ for Eucomed members and non-members. Company size will be considered when fees will be determined.

How does it work in practice?

The Ethical Business Logo is a self-certification system licensed by Eucomed. This implies the following elements:

Certifying companies will have to renew the certification on an annual basis and update, if necessary, information provided in and with the Licence Agreement.
Eucomed Secretariat can randomly check that certifying companies continue to comply with the criteria required to obtain the Logo. Companies are then requested to provide, within 30 days from the request by the Eucomed Secretariat, evidence of the implementation of the above-mentioned obligations (i.e. appointment of a compliance officer, establishment of internal policies procedures transposing the Code internally and provision of comprehensive and regular trainings to employees) are fulfilled. Eucomed plans to randomly confirm compliance to the criteria in at least two licensed companies per year.

What in case of abuse or violation of the Eucomed self-certification or failure to provide evidence?

If an individual, a company, an organisation or Eucomed notices an alleged abuse or violation of the Eucomed self-certification Licence Agreement, they may lodge a complaint with the Eucomed Compliance Panel. The Panel will handle it directly, without intervention of any national panel.

Where the Panel rules that there is an abuse or violation of the Licence Agreement, sanctions will be imposed at the discretion of the Panel (e.g. withdrawal of the Ethical Business Logo, written reprimand, publication of the Panel's decision).

The Procedural framework to lodge a complaint is detailed in the Eucomed Compliance Panel Internal Procedural Rules.

The Ethical Business Logo in the UK: Association of British Healthcare Industries (ABHI)

ABHI launched on 29 September 2011 an identical Logo aimed at UK companies or companies operating mostly in the UK market.

Eucomed recommends that multinational companies active in the UK and other countries choose the Logo licensed by Eucomed. A company mainly active in the UK is recommended to use the Logo licensed by ABHI.

To obtain more information on the ABHI Ethical Business Logo, please visit www.abhi.org.uk

Useful Downloads

Companies already using the Ethical Business Logo

Biomet - Edoardo Lazzarini, Ph.D., European Compliance Officer (November 2011)
Boston Scientific - Kalisa Barratt, Senior Compliance Counsel, EMEA (March 2012)
CareFusion - Tamara Tubin, Director Ethics & Compliance International (January 2012)
Coloplast - Jeppe Kromann Haarsted, Corporate Responsibility Manager, People & Communications (December 2011)
ConvaTec - Humbertus Stockman, Director Ethics & Compliance / CCO EMEA (October 2011)
Covidien - Tracy Palmer Berns, Chief Compliance Officer (December 2011)
Johnson & Johnson - Elaine Murphy, Health Care Compliance Officer, MD&D EMEA (December 2011)
Smith & Nephew - Dr Alison Parkes, Compliance Officer, Smith & Nephew Advanced Wound Management; Lori Reber, Vice President, Office of Ethics & Compliance International and Emerging Markets (November 2011)
Sorin - Brian Sheridan, General Counsel, Vice-President Legal Affairs (December 2011)

More information

Aline Lautenberg
Senior Legal Counsel
E: aline.lautenberg@eucomed.org
T: +32 2 761 22 82