Corporate Responsibility

Circassia recognizes the importance of corporate social responsibility, and seeks to take account of the interests of all the company’s stakeholders, including its investors, customers, suppliers, partners, and employees. Circassia believes that fostering an environment in which employees act in an ethical and socially responsible fashion is critical to its long-term success. Circassia strives to be a good corporate citizen and respects the laws of the countries in which it operates. Consequently, Circassia has adopted a formal Code of Conduct. The code enshrines Circassia’s policies on respecting people, integrity and interactions with those outside the company.

People

Attracting, motivating and retaining a highly skilled workforce is key to Circassia’s long-term success. The company’s policies accord with best practice, and stipulate that there should be equal opportunities and an absence of discrimination for all employees.

Values

Our values, and the behaviors that underpin them, describe the culture of our business.

Passion

— We are passionate and committed about what we do

— We are excited about our products and technology and the impact they will have on patients’ lives

— We take our responsibilities seriously and ensure everything we do is delivered to the appropriate quality

— We thrive on demanding and challenging timelines and seek to exceed expectations and attain our goals

— We are energized to take action, despite obstacles and setbacks

Recognition

— We identify and acknowledge the contribution that individuals make

— We recognize and reward success internally and with our partners

— We understand mistakes are made; our ability to identify them, correct them, and learn from them makes the difference

— We promote the value of the team above that of the individual to achieve positive outcomes

Integrity

— We trust, respect and listen to each other

— We act with honesty, integrity and fairness at all times, we always strive to do the right thing

— We believe in constructively challenging each other and expect to be challenged

— We are not afraid to say “I don’t know” and go and find out

— We promote open communication and collaboration, encouraging, honest, direct, and respectful feedback

— We take ownership for our actions

Drive

— We set ambitious goals and go for them, believing this drives extraordinary behavior

— We persist, despite setbacks, to achieve goals

— We always convey a strong sense of urgency recognizing saving time creates value

— We seek to achieve success even in complex and changing circumstances

— We always aim to meet or exceed our commitments

Effectiveness

— We understand key business drivers and manage our costs effectively

— We continuously seek to improve our performance and develop more effective ways of working

— We always strive to get the best value for money for our requirements and maximize the return on our investment

— We make informed decisions about the levels of expense needed for the business

— We are clear about roles and responsibilities

Diversity

The importance of diversity within Circassia is also reflected in its policies and procedures. The company does not have formal diversity quotas but recognizes that a diverse employee profile is of significant benefit.

Employee welfare and involvement

Employees are regularly provided with information about the company, for example through regular ‘open house’ sessions at which the Chief Executive Officer and other members of the management team present on various topics such as strategic and operational progress, and employee-related policies. Feedback is frequently sought by line managers and the senior management team through team meetings.

Employment, training, career development and promotion of disabled persons

Circassia recognizes the value of diversity at all levels. The company has an Equal Treatment, Equal Opportunities and Diversity policy. This provides that the company will employ and promote employees on the basis of their abilities and qualifications without regard to age, disability, gender, marriage and civil partnership, pregnancy and maternity, race (including color, nationality and ethnic or national origins), religion or belief or sexual orientation. Circassia appoints, trains, develops and promotes on the basis of merit alone.

Health and safety

Circassia is committed to protecting the health and safety of its employees and endeavors to maintain an effective health and safety culture. The company provides ongoing training to individuals who are responsible for health and safety and all staff are notified of health and safety practices. Circassia continuously monitors its health and safety policy and practices to ensure they are robust, appropriate, and reflect changes in best practice.

Ethical and social policies

Circassia is a pharmaceutical and medical devices company and accordingly operates in a highly regulated ethical framework. It complies fully with these laws and regulations. The company has a clear anti-bribery policy which is monitored by the Compliance department.

Sunshine Act

Circassia is committed to promoting transparency of its relationships with healthcare providers. It collects, tracks and reports payments to healthcare professionals and organizations in compliance with the US Physician Payment Sunshine Act.

Human rights

We support the UN Universal Declaration of Human Rights and recognize the obligation to promote universal respect for and observance of human rights and fundamental freedoms for all, without distinction. We comply with all applicable human rights laws.

Product development

Circassia commissions third-party laboratories to conduct the minimum necessary pre-clinical product safety testing in animal models as required by regulatory authorities before commencing clinical studies. We work according to the 3Rs policy relating to preclinical testing (Refine, Reduce, Replace).

Environment

Circassia is committed to minimizing the impact of its activities on the environment. The majority of the Group’s employees operate out of modern office suites, although it also occupies laboratory space in Oxford and has warehouses in Uppsala, Sweden and Morrisville, USA. Accordingly, the company believes that efficient use of energy and materials in those premises, and responsible disposal of hazardous waste, are the most important means of climate protection currently available to it. Office-based initiatives to reduce waste have also been adopted, which include recycling of paper waste, cans, plastics, batteries and printer toners / cartridges. Circassia does not possess or make use of corporate jets or private planes.

Greenhouse gas emission

Circassia considers that its current activities have a low environmental impact. Nonetheless, it still actively seeks to make energy savings in a fashion which is environmentally responsible and cost effective.

Political and charitable donations

Circassia does not make political or charitable donations, although charitable fundraising by employees is encouraged.

Slavery and human trafficking statement

Circassia does not currently meet the turnover threshold which would require it to make a statement pursuant to the Modern Slavery Act 2015. Nonetheless, it is committed to improving its practices to combat slavery and human trafficking. As part of our initiative to identify and mitigate risks we perform due diligence on potential suppliers and distributors and protect whistleblowers, who can raise concerns anonymously through an externally provided reporting service. We are also finalizing a Partner Code of Conduct which will be rolled out in 2017.