Our Commitment to Integrity, Compliance, and Excellence
Version 1.0 | Effective Date: 01 May 2025 | Approved by: Board of Directors | Classification: Internal - All Employees and Directors
Table of Contents
Table of Contents
This Code of Conduct (the "Code") sets out the standards of professional behaviour expected of every individual associated with Torque Pharmaceuticals Private Limited ("Torque" or "the Company"). It establishes a clear framework for making ethical decisions in a complex and highly regulated industry.
Who This Code Applies To
This Code applies to:
How to Use This Code
This Code does not cover every possible situation you may encounter. It is intended to be a guide, a reference point for making sound judgements. When facing a difficult decision, ask yourself:
If the answer to any of these is "no" or "I am not sure", pause and seek guidance from your manager, the Compliance team, or the Ethics Helpline before proceeding.
Torque Pharmaceuticals is guided by five core values. These values are not aspirational statements. They are the minimum standard by which we measure our conduct every day.
Patient First:
Every decision, from drug development to distribution, places the safety and well-being of the patient at its centre.
Integrity:
We act with honesty and transparency in all our dealings, internally and externally.
Scientific Excellence:
We are committed to evidence-based medicine, rigorous research standards, and continuous quality improvement.
Accountability:
We take individual and collective responsibility for our actions and their consequences.
Respect:
We treat all people, colleagues, healthcare professionals, patients, and communities, with dignity and fairness.
Compliance with applicable laws and regulations is not optional. It is fundamental to how Torque Pharmaceuticals operates. Our activities are governed by a range of Indian and international regulatory frameworks.
Key Regulatory Frameworks
Your Responsibility
Every employee is expected to understand the laws and regulations relevant to their role. Ignorance of a regulation is not an acceptable defence. The Compliance team provides training and guidance to help employees remain current. When in doubt, always consult before acting.
Torque Pharmaceuticals exists to improve patient outcomes. Product quality and patient safety are non-negotiable. No commercial pressure, production deadline, or cost consideration will ever justify compromising the integrity of our products.
Good Manufacturing Practices (GMP)
All manufacturing operations must adhere strictly to Schedule M GMP requirements and applicable international standards. Employees in manufacturing and quality functions must
Pharmacovigilance and Adverse Event Reporting
Torque is legally and ethically obligated to monitor the safety profile of its products post-market. All employees, particularly those in medical affairs and sales, must report any adverse events or product quality complaints received from healthcare professionals or patients through the Company's pharmacovigilance system within the timelines prescribed by regulation.
Product Recall
In the event a product recall is initiated, all employees involved must act swiftly, transparently, and in full cooperation with regulatory authorities. The Company's Recall SOP must be followed without exception.
Torque Pharmaceuticals is committed to providing a safe, healthy, and environmentally responsible workplace. A safe facility is not only a regulatory requirement. It is an expression of how much we value the people who work here.
Workplace Safety
Environmental Responsibility
Substance Misuse
Torque maintains a zero-tolerance policy toward the consumption or possession of alcohol or controlled substances on company premises or while performing company duties.
Our relationship with healthcare professionals (HCPs), including physicians, pharmacists, nurses, and hospital administrators, must be grounded in scientific exchange and patient benefit. It must never be influenced by improper inducements.
UCPMP Compliance
All interactions with HCPs must comply with the Uniform Code of Pharmaceutical Marketing Practices (UCPMP) 2024 issued by the Ministry of Chemicals and Fertilizers, Government of India. The UCPMP places strict limits on gifts, hospitality, and payments to HCPs.
Permitted Activities
Prohibited Activities
When in doubt about whether a proposed interaction is appropriate, consult the Medical Affairs or Compliance team before proceeding
All promotional activities for Torque's products must be truthful, accurate, balanced, and consistent with approved product labelling and regulatory guidelines.
Principles of Ethical Promotion
Digital and Social Media
Medical Representatives
Medical Representatives are the face of Torque to the healthcare community. They must be trained on product knowledge and the UCPMP before being deployed. Detailing visits must be documented and periodic audits will be conducted to ensure compliance.
A conflict of interest arises when a personal interest, whether financial, professional, or personal, could impair, or appear to impair, an employee's ability to act in the best interests of Torque Pharmaceuticals. The appearance of a conflict can be as damaging as an actual one
Disclosure Obligation
Employees must proactively disclose any actual or potential conflict to their manager and the Human Resources or Compliance department. Situations that require disclosure include:
Outside Employment
Employees must obtain prior written approval from HR before taking on any secondary employment, consulting assignments, or paid advisory roles that could conflict with their duties at Torque.
Gifts and Hospitality
Employees may not accept gifts, entertainment, or hospitality from third parties that are of significant monetary value, offered with the intent to influence a business decision, or that could create an actual or perceived obligation. Token gifts of a nominal value (not exceeding INR 1,000) received during festive occasions may be accepted provided they are declared.
Torque Pharmaceuticals maintains a strict zero-tolerance policy toward bribery and corruption in any form. We do not offer, pay, request, or accept bribes, whether directly or through intermediaries, to obtain or retain business or to secure an improper advantage.
Applicable Laws
Our anti-corruption policy is governed by, among others:
Interactions with Government Officials
Particular caution must be exercised when interacting with government officials, including employees of public healthcare institutions, drug regulatory authorities, or state-owned hospitals. Any payment, gift, or benefit to a government official, even a seemingly minor one, can constitute a criminal offence.
Third-Party Risk
We are responsible for the conduct of agents, distributors, and consultants acting on our behalf. All third parties must be subject to appropriate due diligence before engagement and must contractually agree to adhere to our anti-corruption standards.
Confidential Information
Employees have access to sensitive and proprietary information as part of their role. This includes product formulations, clinical data, pricing strategies, regulatory submissions, financial information, and business plans. Such information must be protected at all times and must not be shared with unauthorised individuals, inside or outside the Company.
Intellectual Property
All inventions, developments, processes, or discoveries made by employees during the course of their employment are the intellectual property of Torque Pharmaceuticals. Employees must not use or disclose IP for personal benefit or share it with any third party without explicit written authorisation.
Patient and HCP Data Privacy
In accordance with the Digital Personal Data Protection Act, 2023 (DPDP Act) and applicable health data regulations:
The integrity of our research is foundational to the trust patients and healthcare professionals place in our products. Torque Pharmaceuticals conducts all research and clinical studies in accordance with ethical, scientific, and regulatory standards.
Good Clinical Practices (GCP)
Data Integrity
Publication Ethics
All scientific publications arising from Torque-sponsored research must follow ICMJE guidelines. Ghostwriting is prohibited. Any financial relationship with Torque must be fully disclosed in publications and presentations.
Torque Pharmaceuticals is committed to maintaining accurate financial records and a robust system of internal controls. The integrity of our financial reporting underpins the confidence of our investors, partners, and regulators.
Accurate Books and Records
Insider Trading
Employees who have access to material non-public information about Torque or its business partners must not trade in any related securities, or tip off others to do so. This restriction applies during the entire period of employment and extends beyond, as specified in applicable securities laws.
Fraud Prevention
Any suspected financial fraud, including invoice manipulation, expense falsification, procurement fraud, or misappropriation of Company assets, must be reported immediately through the Ethics Helpline or directly to the Chief Financial Officer.
Torque Pharmaceuticals is committed to a workplace where every individual is treated with dignity, respect, and fairness. We do not tolerate discrimination, harassment, or bullying in any form.
Equal Opportunity Employment
We recruit, develop, and promote employees based on merit, competence, and performance, without regard to gender, age, religion, caste, disability, sexual orientation, or any other characteristic protected by law.
Prevention of Sexual Harassment
Torque complies fully with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (POSH Act). We have a constituted Internal Committee (IC) to receive and resolve complaints. All employees are required to attend POSH awareness training annually.
Violence and Threatening Behaviour
Violence, threats of violence, intimidation, or any behaviour that creates fear in the workplace will result in immediate disciplinary action, including termination and referral to law enforcement where warranted.
Diversity and Inclusion
We actively seek to build a diverse workforce that reflects the communities we serve. Inclusive teams produce better science, better decisions, and better outcomes for our patients.
Torque Pharmaceuticals is committed to transparent, honest, and cooperative engagement with all government authorities and regulatory bodies, including CDSCO, the State Drug Controllers, the Competition Commission of India, and any other competent authority.
Regulatory Inspections
In the event of a regulatory inspection or audit, employees must be cooperative, provide accurate information, and inform their functional head and the Legal/Regulatory Affairs team immediately. Employees must not destroy, conceal, or alter records in anticipation of or during an inspection.
Lobbying and Political Contributions
Any engagement with government officials for the purpose of influencing policy or regulation must be conducted through authorised channels and fully documented. Torque does not make direct financial contributions to political parties or candidates.
Torque Pharmaceuticals depends on its employees to speak up when they see something that does not look right. Reporting a genuine concern is not disloyalty. It is one of the most important contributions an employee can make.
How to Raise a Concern
Concerns can be raised through any of the following channels:
Zero Tolerance for Retaliation
Torque strictly prohibits any form of retaliation against an employee who, in good faith, reports a concern or participates in an investigation. Retaliation, including demotion, transfer, exclusion, or any adverse employment action, is itself a serious disciplinary offence.
False Reporting
While we encourage reporting, deliberately false or malicious reports are a breach of this Code and will be subject to disciplinary action.
Torque Pharmaceuticals holds itself accountable not only for its own conduct, but also for the conduct of the third parties with whom it works. Our reputation is shaped by the actions of those who act on our behalf.
Vendor Due Diligence
Contractual Requirements
Material agreements with third parties must include representations and warranties regarding compliance with applicable laws, anti-corruption requirements, and Torque's Supplier Code of Conduct. Failure by a third party to adhere to these standards may result in contract termination.
Responsible Sourcing
Torque does not knowingly source raw materials or services from suppliers who engage in forced labour, child labour, or unsafe working conditions. Suppliers are expected to uphold human rights and environmental standards in their own operations.
Violations of this Code, or of the laws and regulations that underpin it, will be treated with the utmost seriousness. The Company is committed to a fair, consistent, and transparent process for investigating and responding to potential misconduct.
Investigation Process
Consequences of Violations
Depending on the nature and severity of the violation, disciplinary action may include:
Senior leaders are held to a higher standard. Violations of this Code by managers or directors, including failures to detect or prevent misconduct within their teams, will be treated as aggravating factors.
Violations of this Code, or of the laws and regulations that underpin it, will be treated with the utmost seriousness. The Company is committed to a fair, consistent, and transparent process for investigating and responding to potential misconduct.
Mandatory Training
All employees must complete Code of Conduct training:
Code Review
This Code will be reviewed at least once every two years by the Compliance team in consultation with Legal and HR. Amendments will be approved by the Board of Directors and communicated to all employees
