Code of Conduct

This Code of Conduct (the “Code”) outlines practices and guidance that establish foundations of integrity and ethical operations in all efforts undertaken by Profound Research LLC (hereafter “Profound”). This Code applies all employees and collaborators, including Profound Board Members, Executive leadership, Principal Investigators, research staff, vendors, consultants, subcontractors, and any person or entity working for or on behalf of Profound. In conjunction with other policies, business practices, and standard operating procedures, the Code was developed to describe Profound’s mission, vision, and values and to provide guidance and expectations related to the conduct of Profound’s business.

About Profound

Patients are at the heart of Profound’s work. Profound believes deeply that:

• Every patient deserves:
  • Tomorrow’s treatment’s today.
    • Profound connects patients and physicians to advanced therapeutic options through clinical research.
      
  •  The best treatments available.
    • Profound brings trials to patients in their own communities, ensuring that patients have access to cutting edge treatments via clinical research, with the convenience of receiving care from their trusted healthcare providers.
      

• Patients should be at the center of everything.
  • We are committed to delivering compassionate care that is designed to meet the unique needs of each person. Profound enables patients to change the course of their health journey and regain control of their wellbeing.
    

• Everyone can contribute to a better future.
  • By participating in clinical trials, patients can make a real difference in the lives of others facing similar health challenges. We are a community of doctors and patients committed to advancing medical science and discovering new treatments to help people live longer, healthier lives.

Profound’s Mission and Vision

Profound’s Mission is to ensure that every patient has access to innovative treatments and improve patient lives. The future of medical innovation rests in the hands of physicians and their everyday care delivery decisions.

Our Values

• Compassion. We honor the patient-physician relationship above all else;
• Efficiency. We orient for outcomes and strive for process perfection;
• Progress. We contribute to continued innovation in medicine while improving health outcomes; and
• Integrity. We hold ourselves to the highest ethical, quality, and scientific standard in every activity.

Good Business Citizenship and General Business Ethics

Profound requires anyone working for or on behalf of Profound to conduct themselves in interactions with each other, clients, vendors, and all third parties with honesty, respect, and the highest standards of conduct. Profound is committed to the concept of good business citizenship and our work requires careful observance of the spirit and letter of all applicable laws and regulations.

Vendor Management

As the operation of clinical research requires the involvement of many third parties, including vendors, suppliers, and service providers, Profound strives for effective and respectful collaborations focused on Profound’s mission vision, and values. Vendors working for Profound are expected to comply with applicable sections of this code and vendor and supplier relationships must be carefully managed to meet all quality requirements and assure efficient performance and fiscally sound business practices. In procurement decisions, Profound embraces supplier diversity. Profound believes in giving small and traditionally disadvantaged businesses the opportunity to compete for contracts. Profound gives due consideration to these businesses, while evaluating suppliers and service providers for quality, value and ability to best serve the interests of Profound’s business.

Legal and Regulatory Compliance

Clinical research and other aspects of Profound’s business are subject to many rules and regulations. These rules and regulations are designed to honor a patient’s relationship with their physician, protect patients and consumers, eliminate fraud and improper influence, and improve the quality of healthcare services and treatment options. Profound is committed to following the legal requirements that governing our business. This commitment includes compliance with all applicable federal, state, and local laws, including, but not limited to the U.S. Federal Anti-kickback Statute, Foreign Corrupt Practices Act, Food Drug and Cosmetic Act, False Claims Act, and all material and applicable aspects of the PhRMA Code. Profound policies and procedures additionally promote the adherence to FDA guidance, PhRMA Guidelines, and the adoption of industry best practices, where applicable.

Do the Right Thing

Several key questions can help identify situations that may be unethical, inappropriate or illegal. Ask yourself:

• Does what I am doing comply with the Profound values, Code of Conduct and company policies?
• Have I been asked to misrepresent information or deviate from normal procedure?
• Would I feel comfortable describing my decision at a staff meeting?
• How would it look if it made the headlines?
• Am I being loyal to my family, my company and myself?
• What would I tell my child to do?
• Is this the right thing to do?

Responsibility and Reporting

Compliance with this Code is a responsibility Profound takes very seriously. If a person believes that either Profound, a Profound employee, or anyone acting for or on behalf of Profound has violated any applicable law or behaved unethically in the conduct of their business, such person should promptly report the facts of the incident or incidents, names of the individuals involved, and the names of any witnesses to a supervisor or Profound Executive Leadership.

Profound relies on individuals to use their best judgment and all supervisors and Executive Leadership are able to address any concern you have or work with you in resolving any ethical dilemma. If you feel your supervisor has not adequately addressed your concerns or if you are uncomfortable talking about the issue with your supervisor, you can speak to any member of Profound Executive Leadership. The important thing is that individuals do not take any action in violation of this Code.

• In addition to working with your supervisor and Profound Executive Leadership, reporting options are available through the Profound Ethics Line which can be reached in the following ways:
  Email: ethics@profoundresearch.io
• Website: https://www.mycompliancereport.com/report?cid=PRFND
• Toll-Free telephone: 888-893-9057

These options provide the opportunity for anonymous reporting if it is desired.  Profound will promptly, thoroughly, and objectively investigate all claims and will take appropriate corrective action.

No Retaliation

Profound is committed to providing the opportunity to speak up freely and a work environment that is free of any form of retaliation. No adverse action will be taken against any person for reporting any form of unlawful conduct or for reporting, in good faith, a violation of this Code or any Profound Policy. Retaliation is generally defined as any kind of negative action taking the form of punishment or creating a hostile, threatening, or uncomfortable environment.

• Any material change to established working norms that may negatively impact an individual’s experience at work or the ability to fulfill his or her responsibilities;
• Exclusion of an employee from workplace activities, communications, meetings, or discussions;
• Withholding of necessary material, equipment or information;
• Interference with or destruction of personal property;
• Termination or retraction of benefits, demotion, or reduction of compensation;
• Unwarranted, unsatisfactory marks on a performance evaluation;
• Exclusion from company events or isolation in the workplace; or
• Defamation or other malicious reputational damage.

This prohibition of retaliation applies to all official or unofficial reports made in good faith. Profound reserves the right to take disciplinary action against any employee or collaborator for retaliation or for repeated filing of false reports or who has been proven, in reports or investigations, to have been acting maliciously, falsifying evidence, lying, or acting for personal benefit.

Respect for Individuals, Equal Opportunity, and Diversity

In many aspects of the business, Profound is committed to the principles of equal opportunity, inclusion and respect.

• Employment. In making employment decisions, Profound does not discriminate against employees or job applicants based on any characteristic protected under local, state or federal law, including race, color, religion, sex, sexual orientation, national origin, citizenship, veteran status, age, disability, or genetic information.
• Clinical Trials. In clinical research, Profound adheres to guidance from FDA and other regulatory agencies on enhancing the diversity of clinical trial populations and on the inclusion of underrepresented populations in clinical research. Our focus on community-based access to clinical trials, emerging treatment options, and quality healthcare demonstrates Profound’s commitment to equal opportunity and the reduction of healthcare disparities.

Harassment and Bullying

Every staff member has a right to a work environment free from harassment, regardless of whether the harasser is a co-worker, supervisor, manager, customer, vendor or visitor.
Profound respects the personal dignity of all individuals and prohibits bullying and harassment of any kind. Unlawful harassment includes harassment based on race, color, religion, creed, sex, gender identity, sexual orientation, age, disability, national origin or ancestry, as well as citizenship, marital, veteran, and family and medical leave status, or any other status protected by law. Sexual harassment includes harassment of a sexual nature of a person of the same or opposite sex as the harasser.

• Profound defines bullying as repeated, health-harming mistreatment by one or more perpetrators. It is abusive conduct that includes:
  • Threatening, humiliating or intimidating behaviors;
  • Work interference or sabotage; or
  • Verbal abuse 
    
• Specific examples of bullying and harassing behavior are listed below:
  • Verbal. Slandering, ridiculing, or maligning a person or his or her family; persistent name-calling that is hurtful, insulting, or humiliating; using a person as the butt of jokes; abusive and offensive remarks;
  • Physical. Pushing, shoving, kicking, poking, tripping, unwanted physical contact, assault or threat of physical assault, damage to a person's work area or property;
  • Gesture. Nonverbal gestures that can convey threatening or harassing messages; or
  • Exclusion. Socially or physically excluding or disregarding a person in work-related activities.

Health and Safety

Profound is dedicated to maintaining a healthy and safe environment. Profound employees are bound to follow safety procedures specific to their role and various site locations. Safety manuals and training may be available, depending on your work location. Home offices used in remote work should additionally be kept free of hazards. If you have questions of workplace safety, please contact the HR department.

Personal Conduct

While Profound does not seek to interfere with off duty conduct, certain types of off duty conduct may interfere with Profound's legitimate business interests. Employees and other persons working for or on behalf of Profound are expected to conduct their personal affairs in a manner that does not adversely affect Profound's integrity, reputation, or credibility. Off duty conduct that adversely affects Profound's legitimate business interests or the ability to meet expectations at Profound may, subject to applicable law, result in disciplinary action up to and including termination.

Confidential Information

As a condition of most working relationships with Profound, a Profound employee, team member, consultant, subcontractor or anyone working for or on behalf of Profound may have signed a Confidentiality Agreement or other agreement with binding terms and conditions related to the management of confidential information. This information (hereinafter referred to as “Confidential Information”) includes, but is not limited to: data relating to Profound’s customers and clinical trials, trade secrets, commercial strategy, and commercial programs; Profound’s forecasts and revenue, procedures; pricing of services; customer and prospect lists; the identity, authority and responsibilities of key contacts with Profound business partners; details concerning the structure, conditions, and extent of service arrangements; contract expiration dates; proprietary software, web applications and analysis tools; and all information relating to the operation of Profound’s business which Profound may designate as confidential or proprietary or that an employee reasonably knows should be, or has been, treated by Profound as confidential or proprietary. Confidential Information does not include any information that at the time of disclosure is generally known to, or readily ascertainable by, the public or that becomes known to the public through no fault of Profound.
 
To protect Profound’s interest in Confidential Information, an employee or individual with access to Profound Confidential Information must (a) not use any such Confidential Information for his or her own personal benefit or for the benefit of any person or entity other than Profound, (b) use best efforts to limit access to such Confidential Information to those who have a need to know it for the business purposes of Profound, and (c) not disclose, nor permit to be disclosed, any Confidential Information, except as required in the ordinary course of performing employment duties. In addition, employees and other collaborators should minimize occasions on which documents or information may be at risk of loss, damage, theft, misappropriation, or misuse. On occasions where it is necessary for effective job performance to use Confidential Information outside the office, appropriate security measures should be taken.

Conflicts of Interest

 All employees and others working for or on behalf of Profound have a duty to further Profound’s aims and goals, and to work in Profound’s best interest. Employees, and collaborators are expected to use Profound property, opportunity, or information only for Profound’s legitimate business purposes and to avoid conflicts of interest. There are several types of conflict of interest:

• Personal, romantic, social, or relational;
• Financial;
• Competitive; and
• Confidential
  

In no circumstance shall an employee or anyone working for or on behalf of Profound engage in activities that lead to personal gain at the expense of Profound or place themselves in a position where their actions or personal interests may be or appear to conflict with those of Profound. Any involvement that conflicts with responsibilities to Profound or affects or impairs a person’s judgment in decision-making will be considered a conflict of interest. Examples include, but are not limited to: acting on any bias or the appearance of bias reflecting conflicting priorities, using any Profound relationship, information, or asset for personal gain; acting on behalf of someone other than Profound in the performance of job functions; failing to execute the best solution for Profound for personal financial gain, ownership interests, or financial or contractual arrangements with partners, customers, or suppliers of Profound; and acting as director, officer, employee or otherwise for any business or institution which has a competitive or significant business relationship with Profound without Profound’s written approval . The foregoing list of conflicts is not all inclusive. This Code requires that any potential conflict of interest be reported to a supervisor or member of the Profound Executive team. Advance review can protect individuals and Profound. Profound will cooperate to address or resolve any conflict and take any appropriate corrective action. Principal Investigators and clinical trial research staff may be required to submit disclosures to assure that no conflict of interest exists as a condition for their involvement in a clinical trial.

Patient Choice and Clinical Trial Volunteers

Profound respects the right of patient choice and values collaborative consultation with healthcare providers with respect to care. Clinical Trial participants are volunteers, and thus contribute to advancements in medical care through their willingness to enter clinical trials and undergo experimental treatments and procedures. By offering patients access to clinical trials, honoring the independent judgement of healthcare providers and the trusted relationship a healthcare provider has with patients, Profound facilitates enhancements to the quality of care and research innovations. Such advancements can improve outcomes and quality of life for patients, caregivers, families, and our communities.

Research

Profound's policy regarding research is designed to bolster the public trust and Profound’s principled partnerships with industry sponsors and other researchers. Profound clinical trials are conducted in accordance with ethical standards and applicable state and federal regulations, study sponsor requirements, the principles described in PhRMA's Principles on Conduct of Clinical Trials and Communication of Clinical Trial Results, the Federal Food, Drug and Cosmetic Act and International Council for Harmonization of Technical Requirements for Pharmaceuticals for Human Use. All Profound employees, collaborators, investigators and research staff are expected to be familiar with policies, laws and regulations that pertain to their role, and any additional requirements of clinical trial sponsors. All research programs are aimed offering patients access to clinical trials, augmenting the knowledge of study sponsors and the research community, and working towards advances in the prevention, diagnosis, and treatment of disease.

Evaluation and Sharing of Research Data

Profound is committed to facilitating advances in the prevention, diagnosis, and treatment of disease. This commitment involves the accuracy of records and the public disclosure of clinical trial results to study participants as well as to physicians and other members of the scientific community. Profound study sites and investigators are granted certain publication rights regarding site-level data and activities through contractual arrangements with Profound and clinical trial sponsors. Researchers and physicians are expected to retain and exercise independent professional and scientific judgement in any evaluation.

Environmental Responsibility/Sustainability

Stewardship of the environment is a critical aspect of good corporate citizenship and an initiative that is well-aligned with Profound’s objective to make a better future. Profound will operate its facilities to meet all requirements of applicable law, including requirements related to environmental matters. Profound will make decisions with environmental impacts under consideration and will take steps towards sustainability where practicable.

Privacy and Protected Health Information

rofound only collects, uses, shares, stores, or otherwise processes protected information according to applicable law, consistent with a person’s rights, and only with an appropriate basis. The Profound Privacy Policy is located at the following web address: https://profoundresearch.com/privacy-policy.

Profound additionally requires that the confidentiality of patient protected health information (“PHI”) be maintained. Profound and organizations working for and on behalf of Profound may have access to member’s most sensitive information.  Profound takes seriously our duty to comply with and to assure that anyone with access to this sensitive information complies with the Heath Insurance Portability and Accountability Act (“HIPAA”) and other applicable confidentiality requirements.

• The HIPAA Privacy Rule governs the use and disclosure of PHI in all formats (oral, hard copy, and electronic). The Privacy Rule also sets forth specific rights for individuals with respect to their PHI. The Privacy Rule requires covered entities to implement safeguards to ensure the protection of PHI.
• The HIPAA Security Rule provides standards for protecting the confidentiality, integrity, and availability of electronic PHI (“ePHI”). The Security Rule implements the protections contained in the Privacy Rule by setting forth specific administrative, physical, and technical safeguards to secure ePHI. Profound complies with these safeguards.
• The Minimum Necessary Standard requires that for each use or disclosure (apart from uses or disclosures made for treatment purposes), Profound must determine the smallest amount of PHI required to accomplish the purpose and disclose only that amount.

Social Medial and Other Communications

All Profound communications are carefully planned in compliance with Profound Policies and in compliance with applicable law. Only those who are specifically designated will speak as a Profound representative. All external media inquiries should be referred to Profound’s President or Head of Operations. All social media interactions should be respectful, bearing in mind confidentiality obligations to Profound and study sponsors.

Company Property

During the course of their work with Profound, an employee or other individual working for or on behalf of Profound will be provided with and will generate correspondence, memoranda, protocols, study data, literature, reports, summaries, manuals, proposals, contracts, customer lists, prospect lists, and other documents and data concerning the business of Profound. All such records and data, whether maintained on paper or in other hard copy or on a computer or other medium, are the property of Profound, regardless of whether such records contain Confidential Information. Upon termination of the employment or other relationship, all such records must be returned to Profound and employees or others working for or on behalf of Profound may not retain any copy of such records or make any notes regarding such records. Employees should not have any general or specific expectation of privacy in the workplace, either on the premises of Profound or otherwise while working.

Profound reserves the right to search for such information and Profound property in personal items on company premises such as vehicles, purses, briefcases, etc., where consistent with legitimate business purposes and only as permitted by applicable law.

Use of Company Equipment and Other Property

 It is Profound policy that all Company assets, including but not limited to, funds, materials, equipment, and services (such as telephones, fax machines, computers, internet access and email), facilities, know-how and personnel be used only for legitimate Profound business. Employees and others working for or on behalf of Profound may not:

• Use or divert Profound property (facilities, equipment, supplies or time), or the services of any Profound personnel in violation of applicable law or for his or her own advantage or for improper purposes;
• Use corporate letterhead for matters not directly related to Profound business;
• Conduct work unrelated to Profound, including work related to political or charitable activities, at a Profound facility or using Profound assets and resources;
• Damage or destroy property of Profound or clinical trial sponsors through careless or willful actions;
• Engage in communications that may be considered illegal, offensive, defamatory, harassing, obscene, vulgar, or otherwise disruptive to business activity;
• Visit inappropriate or unauthorized internet sites;
• Disseminate copyrighted or licensed materials or confidential and proprietary information; and
• Install hardware or software without appropriate authorization.

Recordkeeping and Retention

Profound prepares all records accurately, reliably, honestly and in accordance with established regulatory, finance, accounting, trial sponsor, and medical record-keeping requirements. Accurate record keeping protects patients and clinical research participants and helps Profound to manage its business. Records include financial statements, billing claims, expense reports, invoices, payroll records, benefit claims, research reports, and medical charts and records. It is against Profound policy to falsify or alter records. There are various laws that require retention of records for specific periods of time. Profound employees or anyone working for or on behalf of Profound should not destroy a record without first verifying the appropriate retention period has expired. Records and documents are not to be destroyed or altered in anticipation of, or in response to, a request for those documents by any government agency or court.

Interactions with Regulatory Authorities and Government Agencies and Officials

 Profound is committed to cooperating with government representatives, officials or law enforcement officers and agents. Profound will respond to requests for information from government agencies and officials under the direction of the Legal Department. Government officials and law enforcement may make announced and unannounced visits to a Profound facility or may approach individuals at a location other than a Profound facility or through personal channels of contact. If you are contacted by a government official or law enforcement in connection with an investigation or request for documents related to Profound’s business, or if you receive a subpoena, demand or other official request related to your role or Profound, you should notify the Legal Department immediately. This Code requires that Profound personnel:

• Seek Legal Department direction;
• Do not volunteer information, answer any questions or hand over any documents or requested items without first contacting the Legal Department;
• Treat government officials and law enforcement with courtesy and respect; and
• Engage with government officials and law enforcement discretely and privately when at a Profound facility.
• Individuals have the legal right not to speak to an investigator.

Insider Trading

During the course of any working relationship with Profound, Profound Personnel may come across material non-public information of Profound or of its customers, partners, or collaborators that could have significant bearing on the valuation of the organization in public or private markets. Such information may include, but is not limited to, non-public information about a company’s financial situation, regulatory status, development programs, clinical developments study results, management changes, potential mergers and acquisitions, litigation, or award or loss of a significant grant or contract. With regard to organizations that are traded publicly, a person may not buy or sell securities of such organization while being aware of material non-public information. Furthermore, employees may not provide such information about any company to others (or provide tips), directly or indirectly, so that any profit may be gained based on knowledge of material non-public information.

False Claims; Fraud, Waste, and Abuse

 All Profound personnel are expected to comply with the Federal False Claims Act and state laws that prohibit sites from knowingly submitting, presenting or causing another person or entity to submit or present false or fraudulent claims for payment of government funds.
 
In the conduct of business and clinical trial administration, Profound does not bill any patient, insurer, or governmental agency for any items, visits, services or expenses that are provided or paid for by, or on behalf of, a clinical trial sponsor.
 
In collaboration with clinical trial sites, Profound takes reasonable precautions to produce billing and coding that is accurate, timely, relevant and in compliance with our policies, clinical trial agreements, as well as federal and state laws and regulations.
 
Clinical trial billing shall be performed in compliance with lawful billing and coding policies, procedures and documentation requirements established by Profound, study sponsors, and third-party payers.
 
To assure the accuracy of billing, Profound expects all trial sites to:

• Document diagnosis, treatment, clinical trial procedures, and all other components of the patient’s record in a timely and accurate manner;
• Generate accurate and truthful records, working with the Profound accounting team to assure that clinical trial sponsors are billed only for services actually provided;
• Follow current coding standards;
• Verify reimbursement expectations of clinical trial sponsors before seeking patient or third-party reimbursement for any procedure related to a clinical trial participant;
• Seek government reimbursement only where allowable;
• Correct billing errors and promptly refund any overpayments; and
• Submit accurate reports as defined by applicable laws and the requirements of clinical trial sponsors. 
  

In addition, all trial sites must comply with the Stark Law which prohibits referrals for certain Medicare and Medicare items and services furnished by an organization with which the referring physician, or his or her immediate family member, has a financial relationship, unless a specific legal exception.

Improper Payments

Profound uses only lawful practices involving payments to healthcare practitioners, political parties, officials, candidates or governmental authorities. As a result, kickbacks and bribes offered with the intent of inducing or rewarding decisions or actions are strictly prohibited. No Profound employee and no other person working for or on behalf of Profound may make, offer to make or accept direct or indirect payments of value in the form of compensation, gifts or contributions in violation of this Code. This applies to gifts, favors, or items of value:

• To or from persons or firms employed by or acting on behalf of an organization (private or governmental) for the purpose of rewarding favorable actions in a transaction.
• To any governmental official, political party or official of a party or candidate for political office, for the purpose of rewarding favorable actions or influence of the official, party or candidate.
• From a company in contravention of the PhRMA Code or for the purpose of exercising influence over such practitioner’s medical judgement or for providing any improper incentive.
• To or from any recipient whose independence and objectivity might be suspected of improper influence.

In addition, employees may not directly or indirectly solicit or accept improper incentives from third parties in an attempt to influence Profound’s actions in favor of such third party. These restrictions apply to money, services, gifts, goods or favors and are not applicable to ordinary and reasonable business expenses. Employees and others working for or on behalf of Profound should exercise sound judgment and discretion, and in all cases, abide by all Profound Policies, with regard to these expenses.

Meals, Business Courtesies, Gifts

Profound employees or anyone working for or on behalf of Profound may accept occasional meals, refreshments, entertainment and similar business courtesies that are shared with the person who has offered to pay for the meal or entertainment, provided that:

• They are not inappropriately lavish or excessive.
• The courtesies are not frequent and do not reflect a pattern of frequent acceptance of courtesies from the same person or entity.
• The courtesy does not create the appearance of an attempt to influence business decisions, such as accepting courtesies or entertainment from a supplier whose contract is expiring in the near future.
• The employee accepting the business courtesy would not feel uncomfortable discussing the courtesy with his or her manager or co-worker or having the courtesies known by the public.

Profound Employees may accept unsolicited gifts, other than money, that conform to the reasonable ethical practices of the marketplace, including:

• Flowers, fruit baskets and other modest presents that commemorate a special occasion.
• Gifts of nominal value, such as calendars, pens, mugs, caps and t-shirts (or other novelty, advertising or promotional items).

Generally, employees may not accept compensation, honoraria or money of any amount from entities with whom Profound does or may do business. Tangible gifts (including tickets to a sporting or entertainment event) that have a market value greater than $100 may not be accepted unless approval is obtained from management. 
 
Physicians, nurses, and other licensed healthcare professionals may not accept gifts that are intended to influence patient care, prescribing behavior, or clinical trial results. Gifts or any transfer of value made to a licensed healthcare professional may be reported to government authorities in compliance with applicable law.
 
Employees with questions about accepting gifts or business courtesies should talk to their managers or the HR department.

Transparency

Profound supports transparency disclosures of the Patient Protection and Affordable Care Act mandated for the purpose of increasing transparency around the financial relationships between manufacturers of drugs, medical devices, biologics, and physicians or teaching hospitals. Clinical trial Sponsors who also manufacture any product covered by Medicare, Medicaid or the Children’s Health Insurance Program report payments to physicians and other healthcare providers. This reporting applies to direct and indirect payments as well as payment made through Profound.

Antitrust Laws

Antitrust laws are relevant to many business decisions. Those who engage in illegal actions in violation of such laws are subject to fines and imprisonment.
These laws protect individuals and organizations from unfair trade practices, promote competition and preserve the free enterprise system. To comply with Antitrust Laws, Profound does not:

• Enter into agreements with competitors to fix prices, wages, or divide markets.
• Enter into non-solicitation agreements unless reasonably necessary to a legitimate business collaboration.
• Steal or misappropriate trade secrets.
• Conduct boycotts.
• Offer bribes or use deceit, intimidation, or other similar practices.

Except when approved by Profound Executive Leadership, Profound personnel are prohibited from communicating with a competitor, directly or indirectly, about prices of goods or services, including physician services.

Political Contributions

Profound respects an individual’s right to make political contributions and engage in political activities of their choosing. While there are various states that allow corporate contributions to political parties and candidates, many laws prohibit or otherwise regulate corporate cash or in-kind political contributions. Profound will respect all applicable laws with respect to contributions the Company may make to any political party or candidate for political office.

Code Violations

Employee or collaborator violations of this Code or other company policy will be managed as a collaboration amongst Profound leadership, the employee’s supervisor, and the Human Resources Department, as applicable. An employee or collaborator may be cited for violations and required to participate in training or re-training as well as other corrective actions. In certain circumstances, Code violations may be of such severity as to result in suspension of responsibilities or termination of employment or business arrangement. Violation of applicable law may additionally result in individual civil or criminal penalties.

Responsibilities

The summary below identifies certain responsibilities regarding this Code. This summary is not exhaustive, and employees and supervisors are required to follow all aspects of Code, including those NOT specifically identified below.

Profound Executive Leadership

Responsibility for enforcement of the Code is shared by Profound Executive Leadership, and all supervisors are accountable for implementing the Code with a responsibility to:

• Ensure current and newly hired employees are trained regarding the Code, Policies, guidance and procedures and operate accordingly.
• Maintain open communication to assure compliance with the Code and to answer questions and resolve concerns of Profound compliance.

Employees and Collaborators

 Employees and collaborators must familiarize themselves with the Code, and all required Policies, guidance and procedures specific to their function. Employees and anyone acting on Profound’s behalf are expected to know and understand the specific laws, regulations, and guidance that apply to their day-to-day activities and at all times must:

• Act in accordance with this Code, and in alignment with Profound’s values.
• Supervise consultants, contractors, suppliers, and service providers with reference to their compliance applicable provisions of this Code.
• Report any violations of this Code to his or her supervisor, Profound Executive Leadership, or the Legal Department.

Compliance with the Code

Nothing in this Code is intended to be in conflict with applicable law.  Failing to comply with this Code could lead to consequences. For employees, such consequences may include disciplinary action, up to and including termination of employment. For consultants, contractors, suppliers, service providers, and other collaborators and anyone working for or on behalf of Profound, such consequences may include the termination of the business relationship. With compliance, Profound can assure that it is operating according to its values of of compassion, progress, integrity, and efficiency. Together, we can Make a Profound Impact.

If you have any questions about these Terms or our Site, please contact us at legal@profoundresearch.io.

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