Atara Supplier Code of Conduct
At Atara, our mission is to transform the lives of patients with serious medical conditions through pioneering science, teamwork and a commitment to excellence. While executing on this mission, we are committed to maintain the highest standards of legal and ethical conduct and to live by our values of transparency, respect, accountability, integrity and trust. We recognize the choices we make for our suppliers must also reflect these values and our commitment.
The Atara Supplier Code of Conduct (“Code”) was created to convey Atara’s minimum expectations to all suppliers of goods and services to Atara. Fundamental to conforming to this Code is the expectation that our suppliers will, in all its activities, operate in full compliance with all applicable laws, rules and regulations.
We expect every supplier to read, understand and agree to the Code and its application to the performance of their supplier responsibilities. Conformance to this Code is required to become or remain a supplier of Atara. Our suppliers are also expected to hold their subcontractors and suppliers accountable to the principles in this Code.
Suppliers shall conduct their business in an ethical manner and act with integrity.
The ethics elements include:
Business Integrity and Fair Competition
All forms of corruption, extortion and embezzlement are prohibited. Suppliers shall not pay or accept bribes or participate in other illegal inducements in business or government relationships, or through the use of intermediaries. Suppliers shall ensure they have adequate systems in place to prevent bribery and comply with applicable laws.
Suppliers shall conduct their business consistent with fair and vigorous competition and in compliance with all applicable anti-trust laws. Suppliers shall employ fair business practices, including accurate and truthful advertising.
Animals shall be treated respectfully, with pain and stress minimized. Animal testing should be performed after consideration to replace animals, reduce the numbers of animals used or refine procedures to minimize distress. Alternatives should be used wherever scientifically valid and acceptable to regulators.
Data Privacy and Security
Suppliers shall safeguard and make only proper use of confidential information to ensure that company, worker, patient, subject, and donor privacy rights are protected. Suppliers shall comply with applicable privacy and data protection laws and ensure the protection, security and lawful use of personal data.
Patient Safety and Access to Information
Suppliers shall ensure that adequate management systems are in place to minimize the risk of adversely impacting on the rights of patients, subjects and donors, including their rights to health and to access information directly.
Conflicts of Interest
Suppliers shall take reasonable care to avoid and manage conflicts of interest. Suppliers are expected to notify all affected parties if an actual or potential conflict of interest arises.
Identification of Concerns
All workers should be encouraged to report concerns or illegal activities in the workplace, without threat of reprisal, intimidation or harassment. Suppliers shall investigate and take corrective action if needed.
When engaged in clinical trials on Atara’s behalf, suppliers must conduct such clinical trials in accordance with the global standards of Good Clinical Practices, applicable local regulatory requirements and following the ethical principles originating from the Declaration of Helsinki.
Suppliers shall ensure compliance with all applicable import and export controls, sanctions and other trade compliance laws, regulations and rules of the United States and of any country where such transactions occur.
Human Rights and Labor
Suppliers shall be committed to uphold the human rights of workers and to treat them with dignity and respect.
The Labor elements include:
Freely Chosen Employment
Suppliers shall not use forced, bonded, indentured or involuntary prison labor.
Child Labor and Young Workers
Suppliers shall not use child labor. The employment of young workers below the age of 18 shall only occur in non-hazardous work and when young workers are above a country’s legal age for employment or the age established for completing compulsory education.
Suppliers shall provide a workplace free of discrimination. Discrimination for reasons such as color, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership or marital status is not tolerated.
Suppliers shall provide a workplace free of harassment, harsh and inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers or threat of any such treatment.
Wages, Benefits and Working Hours
Suppliers shall pay workers according to applicable wage laws, including minimum wages, overtime hours and mandated benefits. Suppliers shall communicate with the worker the basis on which they are being compensated in a timely manner. Suppliers are also expected to communicate with the worker whether overtime is required and the wages to be paid for such overtime.
Freedom of Association
Open communication and direct engagement with workers to resolve workplace and compensation issues is encouraged. Suppliers shall respect the rights of workers, as set forth in local laws, to associate freely, join or not join labor unions, seek representation and join workers’ councils. Workers shall be able to communicate openly with management regarding working conditions without threat of reprisal, intimidation, or harassment.
Health and Safety
Suppliers shall provide a safe and healthy working environment, including for any company-provided living quarters.
The health and safety elements include:
Suppliers shall protect workers from over exposure to chemical, biological and physical hazards, physically demanding tasks in the workplace and in any company-provided living quarters.
Suppliers shall have programs in place to identify the risks from chemical and biological processes and to prevent or respond to catastrophic release of chemical or biological agents.
Emergency Preparedness and Response
Suppliers shall identify and assess emergency situations in the workplace and any company provided living quarters and minimize their impact by implementing emergency plans and response procedures.
Safety information relating to hazardous materials, including pharmaceutical compounds and pharmaceutical intermediate materials, shall be available to educate, train and protect workers from hazards.
Suppliers shall operate in an environmentally responsible and efficient manner, and they shall minimize adverse impacts on the environment. Suppliers are encouraged to conserve natural resources, to avoid the use of hazardous materials where possible and to engage in activities that reuse and recycle.
The environmental elements include:
Suppliers shall comply with all applicable environmental regulations. All required environmental permits, licenses, information registrations and restrictions shall be obtained, and their operational and reporting requirements followed.
Waste and Emissions
Suppliers shall have systems in place to ensure the safe handling, movement, storage, recycling, reuse or management of waste, air emissions and wastewater discharges. Any waste, wastewater or emissions with the potential to adversely impact human or environmental health shall be appropriately managed, controlled and treated prior to release into the environment.
Spills and Releases
Suppliers shall prevent and mitigate accidental spills and releases to the environment.
Suppliers shall take measures to improve efficiency and reduce the consumption of resources.
Sustainable Sourcing and Traceability
Suppliers shall carry out due diligence on the source of critical raw materials to promote legal and sustainable sourcing.
Suppliers shall use management systems to facilitate continual improvement and compliance with the expectations of these principles.
The management systems elements include:
Commitment and Accountability
Suppliers shall demonstrate commitment to the concepts described in this document by allocating appropriate resources.
Legal and Customer Requirements
Suppliers shall identify and comply with applicable laws, regulations, standards and relevant customer requirements.
Suppliers shall have mechanisms to determine and manage risks in all areas addressed by this document.
Suppliers shall maintain documentation necessary to demonstrate conformance with expectations contained in this document and compliance with applicable regulations.
Training and Competency
Suppliers shall have a training program that achieves an appropriate level of knowledge, skills and abilities in management and workers to address these expectations.
Suppliers are expected to continually improve by setting performance objectives, executing implementation plans and taking necessary corrective actions for deficiencies identified by internal or external assessments, inspections and management reviews.
Identification of Concerns
All workers shall be encouraged to report concerns, illegal activities or breaches of the principles contained in this Code in the workplace without threat of or actual reprisal, intimidation or harassment. Suppliers shall investigate and take corrective action if needed.
Suppliers shall have effective systems to communicate the principles contained in this Code to workers, contractors and suppliers.
Suppliers shall develop and implement appropriate business continuity plans for any and all operations supporting Atara’s business.