Compliance

Our Code of Conduct & Ethics
Valneva is committed to conducting business ethically and responsibly and in compliance with applicable laws, rules and regulations. The Management Board and the Supervisory Board have adopted this Code of Conduct & Ethics, because they firmly believe it is in the long-term interest of Valneva for business to be conducted in compliance with the principles and Valneva values set out in the Code of Conduct & Ethics.

To view the Valneva Code of Conduct & Ethics, click here. 

Our Compliance & Ethics Policies
The Corporate Compliance & Ethics framework at Valneva consists of additional policies including e.g. the Global Anti-Bribery and Anti-Corruption Policy, the Global Conflicts of Interest Policy, the Data Protection Policy, the Global Anti-Harassment, Anti-Discrimination and Anti-Bullying Policy and the Non-Retaliation and Non-Retribution Policy. Furthermore, we have clear rules and limits on any transfer of value to health care professionals and adopted the US PhRMA Code.

Our Compliance Organization
Valneva's Corporate Compliance Officer leads the implementation and development of our Compliance Program. The Local Compliance Officers and other stakeholders form the Compliance Committee and share best practices with implementing measures at our different sites. All employees know whom to contact for questions and for reporting issues, and for those who want to do this anonymously, as permitted by local laws and\or regulations, we offer a dedicated hotline, operated by a third-party provider.

Training Measures
We train our employees on our policies and guidelines on a regular basis. These training measures include classroom training sessions as well as eLearning and are mandatory for employees, external workforces and external partners who perform compliance relevant activities for Valneva.

Checks and Consequences
Valneva performs internal compliance audits to improve processes and detect possible misconduct at an early stage. Compliance with rules and regulations, including attendance of mandatory training measures, is part of every employee's annual goals. Non-compliance has immediate effect on the employees' annual performance and will lead to appropriate consequences. Any internal investigations are based on a dedicated case management process, which includes mandatory corrective and preventive actions and adequate reporting to the relevant decision bodies.

If you need detailed information, please feel free to contact a member of our compliance organization, toll-free, at (833) 403-8778 or email compliance@valneva.com.

Valneva statement regarding compliance with California Health & Safety Code § 119402

NOTICE: This information is provided pursuant to the requirements of California Health & Safety Code, Section 119402, which requires pharmaceutical companies doing business in California to make available their Compliance Program and annual written declaration of compliance with the Compliance Program.

California Health & Safety Code, Sections 119400 – 119402, (“California Compliance Law”) requires pharmaceutical companies to adopt a compliance program in accordance with the April 2003 publication “Compliance Program Guidance for Pharmaceutical Manufacturers” (“OIG Compliance Guidance”) developed by the United States Department of Health and Human Services Office of Inspector General (“OIG”) and policies for compliance with the Pharmaceutical Research and Manufacturers of America (“PhRMA”) “Code on Interactions with Health Care Professionals” (“PhRMA Code”) within six months of any update or revision of the PhRMA Code. Revisions to the PhRMA Code were implemented in January 2009, October 2019 and January 2022.

Valneva has established a specific annual dollar limit which applies to promotional materials, items, and activities provided by an employee of relevant Valneva businesses to covered recipients in California. The following expenses are excluded from the limit: drug samples given to physicians and healthcare professionals intended for free distribution to patients, financial support for continuing medical education forums, and financial support for health educational scholarshipsand payments made for legitimate professional services provided by a health care or medical professional, provided that the payment does not exceed the fair market value of the services rendered as well as and any meals or expenses associated with the provision of such services. All payments are provided in a manner that conforms to the "Compliance Program Guidance for Pharmaceutical Manufacturers" and with the "Code on Interactions with Health Care Professionals".

Annual Declaration 2023
To the best of its knowledge, and based on a good faith understanding of the statutory requirements, Valneva has established a Compliance Program that meets the requirements set forth in California Health & Safety Code, Sections 119400-119402 and declares that, it is, in all material respects, in compliance with the Compliance Program as of December 31, 2022.

Third Party Compliance Information
Valneva expects third-party suppliers, service providers, agents, consultants, distributors and business partners to also conduct business ethically and responsibly and in compliance with all applicable laws, rules and regulations. Valneva provides third-party training with regard to anti-bribery and anti-corruption and related compliance topics including the Code of Conduct & Ethics, confidential information, gift giving, conflicts of interest and political activity. Valneva requests third-parties to certify under this training program when doing business with Valneva.