Ethics and Compliance

We can turn transformative breakthroughs into treatments because we have the right qualities and capabilities to deliver new drugs. This includes how we conduct ourselves as we go about our day-to-day work. We hold ourselves to the highest ethical standards. But this is more than merely following a code of conduct or following regulations, we practice these ethical values and behaviors every day. We know what is right and live by it.


We have laid out the principles of our ethical conduct in two key documents:

Model 231

Model 231 is a comprehensive document that promotes and values the conduct that ensures the development of an ethical culture for anyone working on behalf of Dompé.

We have adopted the Organizational, Management and Control Model in accordance with the provisions of the Italian Legislative Decree No. 231 of 8 June 2001 (Model 231). With the European Union and The Organization for Economic Co-operation and Development (OECD) having already issued conventions on the fight against corruption, this decree established, for the first time in Italy, corporate responsibility for crimes perpetuated in the interest or to the advantage of a legal entity.

In our implementation of Model 231 we also considered industry guidelines as set out by the Italian Pharmaceutical Industry Association together with the specific initiatives we already had in place with regard to internal control and corporate governance.

Code of Conduct

An integral part of Model 231 is our Code of Conduct, which provides all the information we need to perform our jobs ethically whilst protecting the Company’s reputation.

Our Code, together with company policies, gives us the information to perform our job ethically and to protect the Company’s reputation by establishing business relationships based on mutual trust. The four key principles that guide our business conduct include:

Compliance: We follow the rules.

Integrity: We are inspired by honesty.

Transparency: We are transparent in all decisions and actions.

Respect: We trust and respect each other.


In our pursuit of delivering what patients need from science, it’s crucial we act with transparency in all decisions and actions. Being transparent helps build strong and authentic relationships with patients, stakeholders and the wider scientific community.

We believe in the Power of Transparency. If something is transparent and available in the public domain, it makes you scrutinize your actions and how others perceive them. The more transparent you are, the more trust people will have in your company. This symbiotic relationship allows us to work to the highest standards.

Transparency is a crucial tool in compliance. At Dompé, we comply with several transparency regulations. For instance, we comply with the European Federation of Pharmaceutical Industries and Associations (EFPIA) Disclosure Code. This Code is a voluntary commitment that requires pharmaceutical companies to disclose transfers of value made to healthcare professionals and healthcare organizations.

Dompe’s transfers of value can be viewed at the following links: