Agios Global Social Media Policy PDF

Social Media GLOBAL POLICY WHAT IS THE PURPOSE OF THIS POLICY? WHO CAN I CONTACT WITH QUESTIONS? The purpose of this policy is...

Social Media GLOBAL POLICY WHAT IS THE PURPOSE OF THIS POLICY? WHO CAN I CONTACT WITH QUESTIONS? The purpose of this policy is to establish consistent compliance If you have any questions about how to comply with this standards for Agios’ social media interactions with customers, policy, please contact a member of the Compliance team. patients, investors, media and employees. These standards are intended to help protect Agios’ confidential information, reputation and goodwill and maintain Agios’ compliance REPORTING VIOLATIONS with applicable local laws, regulations, and industry codes and guidelines (“applicable laws”). Any knowledge of a violation, or suspected violation, of this policy must be reported. Reports can be made to your manager, HR, Compliance WHAT DOES THIS POLICY APPLY TO? or Legal. These standards apply to social media activity, whether on Reports can also be made anonymously via the or off duty, whether using company information systems Agios Compliance Helpline: or personal electronic resources, and whether an Agios employee posts (i) using his or her real name, (ii) under an  (800) 792-8135 assumed name or (iii) anonymously.  www.agios.ethicspoint.com These standards do not apply however, to an Agios employee’s Agios prohibits retaliation against anyone for personal use of social media outside of work, using their reporting, in good faith, a suspected violation own electronic resources, if in a manner unrelated to of the Code of Business Conduct and Ethics, Agios’ business, products, disease states, employees in a company policy or the law. their professional capacity, customers, patients, suppliers, vendors, business partners or competitors. WHO DOES THIS POLICY APPLY TO? TRAINING This global policy applies to all Agios employees worldwide. Appropriate Agios employees shall undergo periodic training When Agios employees engage in social media activity that covering social media activity and the considerations set forth identifies them as an Agios employee, they should use their in this policy and related policies. Training should occur on best judgment and consider whether the comments conform a schedule and in a format to be determined by Compliance. to these standards. This policy is intended to be read together with all applicable Compliance Handbooks (“Compliance Handbooks”) adopted by Agios. Each Compliance Handbook sets out requirements to comply with applicable laws, some of which may impose more stringent requirements than set forth in this global policy. If there is a conflict between this policy, a Compliance Handbook or an applicable law, Agios employees must comply with the strictest standard. Agios employees are responsible for complying with this policy and with any applicable Compliance Handbooks and for ensuring that any contractors or third parties engaged by them to act on Agios’ behalf are subject to a written agreement approved by Legal and adhere to the principles in this policy and applicable Compliance Handbooks. This document is confidential and proprietary and is the exclusive property of Agios. Page 1 of 4 It may not be reproduced in any form without prior written approval from Agios. Version 1.0 | Effective Date: January 1, 2022  Social Media GLOBAL POLICY POLICY would also violate the Code of Business Conduct and Ethics in an online forum. Employees should not engage in social Agios employees may engage in social media communications media communications that violate any laws, such as laws with individuals and entities inside and outside of Agios. governing product promotion, intellectual property and Social media includes any online communications such as privacy. For example, outside the United States, Agios writing a blog or microblog (for example, using Twitter) or employees may not refer to any company products in posting on social media or related platforms (for example, any of their social media activities, nor may they “like”, Facebook, Instagram, Youtube, LinkedIn, CafePharma). link to or re-post any communications, including official Unless Agios has granted express permission to engage in Agios social media communications, that reference any such communications on behalf of Agios, Agios employees company products. may make social media communications only in their personal capacity. In these circumstances, company employees, and 1.3. Communications Regarding Agios and Use of a not Agios, are legally responsible for their social media Disclaimer communications and should ensure the accuracy of the Agios employees are not authorized to speak on behalf of information posted. Such communications nevertheless Agios or promote Agios’ products unless explicitly given should adhere to the general guidelines set forth in this permission in accordance with company policies and policy and in Agios’ Code of Business Conduct and Ethics. procedures. When expressing a personal opinion about Agios Where granted express permission, certain company online, employees must comply with the following and any employees also may engage in social media communications limitations set forth in applicable Compliance Handbooks. on behalf of Agios, so long as such communications adhere Such limitations include the following: to general legal considerations that apply to other content published by or on behalf of the company. In addition, such E  mployees may not make statements or offer endorsements communications must comply with applicable Agios policies or other opinions about Agios’ current or potential products, and procedures, including those outlined in this policy and or Agios’ competitors or competitors’ products. in applicable Compliance Handbooks. E  mployees may not reference Agios or its competitors in social media communications relating to any disease or 1. GENERAL GUIDELINES FOR SOCIAL MEDIA therapeutic area related to a current or potential company ACTIVITY products. The following general guidelines apply to any employee’s social media communications, whether in an employee’s I f employees reference Agios products or services in personal or professional capacity. social media communications, they should do so in a knowledgeable and accurate, manner. 1.1. Be Respectful A  gios employees outside the United States may not use Always be fair and courteous to Agios employees, customers, social media communications to promote Agios’ products vendors, patients, business partners, competitors and other in any circumstances. Such employees may not refer to individuals or entities. Avoid using statements, photographs, any company products in their personal social media video or audio that could be viewed as malicious, obscene, communications, nor may they “like”, link to or re-post any embarrassing, threatening or intimidating, that defames or communications that reference any company products disparages, or that might constitute harassment or bullying. even if those other communications are non-promotional and/or are official Agios social media communications. 1.2. Follow the Code of Business Conduct and Ethics and Unless so authorized by the company, Agios employees Comply with Applicable Laws should not represent or suggest that they are authorized Agios’ Code of Business Conduct and Ethics applies to the to speak on Agios’ behalf, or that Agios has reviewed or social media activity of Agios employees and directors. If approved the content. If that will not be obvious from the the social media activity would violate the Code of Business content or context of the post, Agios employees should make Conduct and Ethics in a forum outside of social media, it it clear to readers that the views expressed are personal and do not reflect the views of Agios. This document is confidential and proprietary and is the exclusive property of Agios. Page 2 of 4 It may not be reproduced in any form without prior written approval from Agios. Version 1.0 | Effective Date: January 1, 2022  Social Media GLOBAL POLICY 1.4. Maintain Confidentiality and Privacy use Agios’ IP in any posting whether related to the terms or conditions of their employment or engagement or otherwise Agios employees may not disclose in any manner (e.g., in that disparages Agios’ brand, products or services. Agios writing, images, audio, video or other content) any confidential employees should not use Agios’ IP in a way that suggests information, including trade secrets, confidential scientific or they are representing Agios or while engaging in conduct business information, or other material nonpublic information that violates company policy. concerning Agios or any other company such as a business partner, supplier or collaborator, if that information was 1.6. Use of Company Email obtained in the course of the employment or engagement with Agios. Trade secrets may include information regarding Unless expressly authorized, Agios employees should not the development of systems, products, know-how and use their company email addresses to register for social technology. Confidential business information may include media. Employees may reference Agios as their employer and material nonpublic information and Agios’ attorney- include contact information only on social and professional client communications or other internal business-related networking sites, such as LinkedIn, or when authorized by confidential communications. If an Agios employee has Agios, without posting a disclaimer. signed a confidentiality agreement with Agios, he or she must adhere to the specific terms in that agreement. 1.7. Using Social Media at Work Employees may not disclose information about individuals Company information systems must be used primarily for without their consent, including any written or electronic company business. Employees may use company information information that relates to an identified or identifiable systems to access and participate in social media, provided that person, or any images or videos of individuals. This includes such social media use does not interfere with the employees’ information about Agios employees, former employees or (or their co-workers’) work commitments, performance or contract workers, applicants for positions within Agios, productivity. If an employee is participating in social media independent contractors, or other individuals associated with forums during working hours or using company resources, Agios or company activities, including patients, physicians and the employee may not make social media communications other customers of Agios. For example, employees may not: that are defamatory, hateful, pornographic, or harassing, or that advocate violence or violations of law or are otherwise E  lectronically communicate photos, videos or other media in conflict with Agios Code of Conduct and policies. when engaged in social media activity without the consent of all those exhibited in such media. Company-provided computers, cell phones, and other communication devices, and any communications that are T  ag, identify or comment on anyone in any social media produced using them, are neither private nor confidential, without such person’s consent. and may be viewed or monitored at any time without the Agios employees also should not disclose personally employee’s consent. identifying information including but not limited to personal contact information, national identification numbers (e.g., 1.8. Report Adverse Events and Product Complaints Social Security numbers), credit or debit card numbers or Agios employees who encounter information concerning financial account numbers of Agios’ employees, customers, an adverse event or product complaint related to any of vendors, competitors, or other individuals or entities. For Agios’ products on social media must report the information additional guidance, refer to Agios’ Global Privacy Policy. immediately (within one business day) consistent with Company’s Corporate Patient Safety Policy. 1.5. Use of Company IP Agios employees should not use Agios’ logo, trademark or proprietary graphics (“IP”) for any purpose on social media, such as promoting any product or service, without Agios’ prior written consent. Additionally, Agios employees should not This document is confidential and proprietary and is the exclusive property of Agios. Page 3 of 4 It may not be reproduced in any form without prior written approval from Agios. Version 1.0 | Effective Date: January 1, 2022  Social Media GLOBAL POLICY 2. COMPANY-SPONSORED SOCIAL MEDIA 3. SOCIAL MEDIA INTERACTIONS WITH ACTIVITY PATIENTS AND PATIENT ORGANIZATIONS Only authorized individuals may engage in company- Where authorized, Agios employees may share information sponsored social media activity, including discussing Agios’ with Patient Organizations or Patients via approved company products and responding to misinformation about Agios’ social media accounts subject to the requirements of this products. All company-sponsored social media activity policy and other applicable Agios policies. Agios employees related to Agios’ products must adhere to Agios’ Global should never engage with Patient Organizations or Patients Policy on Interactions with Healthcare Professionals and via their personal accounts on behalf of Agios or give the Healthcare Organizations and Global Policy on Interactions impression that they are representing Agios unless expressly with Patients and Patient Organizations, and applicable authorized. laws related to such communications, including requirements Agios personnel should generally avoid direct one-on-one for prescription drug promotion. Any medium that does not communications with individual Patients through social media allow for all legally required information to be presented on behalf of Agios, except that authorized Agios personnel generally may not be used for company-sponsored social may respond to individual Patient requests or questions media activity. subject to Agios’ policies and procedures. All social media posts must be reviewed and approved by Agios shall not direct Patients or Patient Organizations (or the appropriate internal review team prior to being posted their representatives) to post information or data about by authorized employees. Agios-sponsored social media Agios or its products or services except pursuant to a written content must clearly disclose that it is sponsored by Agios. agreement specifically authorizing such direction. In such In most instances, either during or after any live event, it cases, Agios’ involvement must be clearly acknowledged. likely will be appropriate to disable features that permit In certain instances, and subject to Legal approval, it third parties to comment on Agios social media posts. All may be permissible for Agios to share publicly available company-sponsored social media activity must comply with information with Patient Organizations that they can, at considerations set forth in applicable Compliance Handbook. their sole discretion, repost on social media. Nothing in this policy is intended to restrict unprompted Patients or Patient Organizations from reposting publicly available information about Agios products or services at their discretion. 4. DEFINITIONS Please see definitions in the Global Healthcare Compliance Glossary. This document is confidential and proprietary and is the exclusive property of Agios. Page 4 of 4 It may not be reproduced in any form without prior written approval from Agios. Version 1.0 | Effective Date: January 1, 2022