Immunocore Ltd is committed to lawful and ethical business operations, including adhering to all applicable laws, regulations, and codes of the countries in which it operates. Our commitment to integrity and transparency is fundamental to earning and maintaining the trust of our patients, healthcare providers, regulators, and the communities we serve.
To ensure we meet our ethical and legal obligations, Immunocore has established a comprehensive Compliance Program that is rigorously enforced across all levels of our organization. Our Compliance Program is based on government expectations, global industry codes, and best practices to effectively mitigate risk throughout our organization.
We continuously review and update our program to prevent, detect, and resolve any instances of non-compliance and misconduct, and to meet our evolving compliance needs.
Written Policies and Procedures:
As part of our commitment to the highest standards of ethical conduct, Immunocore has implemented written policies and procedures consistent with applicable laws and regulations. These written standards are reviewed regularly to ensure their accuracy in an evolving healthcare regulatory environment as well as their relevance to Immunocore’s operations.
Compliance Officer & Compliance Committee:
The Chief Compliance Officer along with the Compliance Department are responsible for overseeing the implementation and execution of Immunocore’s Compliance Program. The Chief Compliance Officer has a direct line of communication to the Chief Executive Officer and to the Board of Directors. Immunocore has also established a Corporate Compliance Committee that meets at least quarterly to meet the Company’s compliance needs.
Training and Education:
A vital component of our Compliance Program involves educating and training our employees and contractors about their legal and ethical responsibilities in accordance with relevant policies, laws, and regulations. Immunocore is dedicated to ensuring that our policies, standards, and procedures are clearly communicated to all staff and business partners. We consistently review and refresh our training initiatives and identify new areas for training as required to maintain compliance and integrity.
Monitoring and Auditing:
Immunocore conducts monitoring and auditing to ensure that our business activities are compliant with our policies and procedures, applicable laws, and regulations. The Compliance Department identifies potential risk areas to focus our monitoring and auditing activities. The frequency and extent of our monitoring and auditing efforts are based on various factors, including the changing regulatory environment and changes in business practices.
Lines of Communications:
Immunocore is dedicated to fostering a culture that promotes open communication between management and employees about our Compliance policies and procedures. We strive to ensure that every employee knows who to approach for any questions and to report any potential violations—without fear of retribution or retaliation. In support of this, we have embraced principles of anonymity, confidentiality, and non-retaliation for any employee who reports or makes a good faith effort to report suspected misconduct or improper behavior. Employees are encouraged to speak up about suspected violations and have several options for making reports, including our hotline and the whistleblower and ethics portal.
Corrective and Disciplinary Action:
Immunocore treats every report of potential or actual breaches of company policy and applicable laws with the utmost seriousness, aiming to quickly resolve any questions and concerns that arise. Our primary objectives are to promptly identify and correct any inappropriate actions, prevent their future occurrence, and facilitate continuous improvement. We thoroughly investigate all significant compliance matters, regardless of whether they are potential, suspected, or confirmed violations of laws or policies. In cases where a substantiated violation is identified, we conduct an analysis. Following the investigation, we engage with relevant stakeholders to determine the appropriate corrective and preventive actions to take in response.
Continuous Improvement:
Our Compliance Program is dynamic. We regularly review and update our policies and practices to adapt to new regulatory changes, industry standards, and internal company developments.
California Health and Safety Code
Effective July 1, 2005, California Health & Safety Code, Sections 119400 – 119402, (“California Compliance Law”) requires that certain pharmaceutical companies doing business in California 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 adopted in January 2009, October 2019, and January 2022.
Immunocore’s current policies support adherence to the voluntary guidelines that California law will now enforce. Immunocore has adopted policies and programs establishing the formal annual dollar limits required by the law and monitors performance against those limits. For purposes of compliance with the requirements of the California Compliance Law and as part of the Compliance Program, Immunocore has established a specific annual aggregate dollar limit of $2000 on gifts, promotional materials, or items or activities that Immunocore may give or otherwise provide to an individual medical or healthcare professional in California on an annual basis from January 1st to December 31st. This limit is in effect until June 30, 2025. Immunocore may periodically re-evaluate this limit and make any updates as necessary.
A description of our Compliance Program and a copy of this annual declaration are publicly available on our website.
Contact Us
For questions about our Compliance Program or to report a potential compliance issue, please contact our Compliance Office at:
Phone:
UK Compliance hotline (toll free): 08000232968
US Compliance hotline (anonymous): (877) 657-5005
Whistleblower and Ethics Portal (Anonymous): Whistleblower and ethics portal (anonymous): https://www.whistleblowerservices.com/IMCR/
Immunocore’s Code of Business Conduct and Ethics: https://immunocore.com/investors/corporate-governance/governance-documents