TML SOP No: XXXX

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Document Status Draft Revised Authorized Invalid

Transmarine Logistics Asia PTE Ltd (TML)

Standard Operating Procedure

TML
Conflict of Interest
SOP Number Version Last Updated

XXXXX 4 01 Aug 2018

Valid From: 01 August 2018 Department: Operations

Transmarine Logistics Asia PTE Ltd

Valid Till: 01 August 2021 Division: (TML)

Authorization Matrix
Prepared By Designation Department Signature Date
Rahid Quality &
Senior Manager
Chowdhury Compliance
Reviewed By Designation Department Signature Date
Supply Chain &
Htet Htet Aung General Manager
Operation
Approved By Designation Department Signature Date

Sk Al Emran Country Head MGH HealthCare

Distribution List
Position Role
Director
Head of Operations
Head of Quality Assurance and Supply Chain

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 TML SOP No: XXXX
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1. Purpose:
The purpose of this report is to manage and identify areas of interest to mitigate or prevent any
sort of conflict between internal and external parties.

2. Scope:

This Policy applies to all employees in Transmarine Logistics Asia PTE Ltd, directly or
indirectly connected.

These Policies are globally standardized. In some countries, more stringent applicable laws and
regulations supersede the principles set out in this Policy.

3. Archival Period:
The master copy of this SOP has to be archived at TML Head Office (DHO) for three (3) years
with acknowledgement record sheet. After the date of expiry, one original copy of this SOP has
to be preserved at DHO.

3. Responsibility:

Sl. Position Responsibility

Ensure that appropriate systems and resources are

3.1 Director
incorporated to handle conflicts of interest.

Ensure validated monitoring system throughout the

organization.
3.2 Head of Operation
Strictly maintain a monitoring system to preserve employee
interests.

Arrange proper training for people involved in the

organization.

Ensure periodic inspection, reporting and follow-up

Head of Quality Assurance
3.3
and Compliance
Corrective and Preventive Action (CAPA).

Validate every preventive measure and process to maintain

this SOP.

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 TML SOP No: XXXX
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4. Procedure:

a) No personal relationships or interest or activities of any sort should influence our

personal judgments while doing business with other engaged parties. This also applies
to the suppliers and other third parties indirectly involved in Transmarine Logistics Asia
PTE Ltd’s business. If anything of that sort takes place, the line manager should be
informed immediately.

b) No employee is allowed to perform paid/unpaid work outside of Transmarine Logistics

Asia PTE Ltd unless there is a signed/written approval from his/her line manager.

c) If members associated with Transmarine Logistics Asia PTE Ltd limited performs
paid/unpaid work related to treating patients, donating products or using or purchasing
or providing reimbursement of them, a written/signed document is needed to show the
approval given by the Head of Department (HOD).

d) All approvals are subject to scrutiny to cross check whether it interferes with
Transmarine Logistics Asia PTE Ltd.’s business interest or not.

e) Even after approval, the employee must ensure that his decisions are not biased. In case
of these situations, A COI form should be filled to keep record. A COI form is basically
an online platform (anonymous if needed) to see whether someone is involved in
multiple interests, financial or otherwise, and serving one interest could involve
working against another. Therefore, this form oversees whether a conflict of interest
can be discovered and voluntarily defused before any corruption occurs.

f) No employee should use Transmarine Logistics Asia PTE Ltd.’s resources for their own
personal benefits.

g) No employees should misuse Transmarine Logistics Asia PTE Ltd.’s sensitive confidential
information for personal or any other purpose.

5. References:

a. WHO Good Distribution Practices Annex- 5

b. Code of Pharmaceutical Marketing Practices-DGDA

6. Document History:
Description Author Date Version

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 TML SOP No: XXXX
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CONFLICT OF INTEREST FORM

Title: Click here to enter text.

Name: Click here to enter text.
Employee ID: Click here to enter text.

Transmarine Logistics Asia PTE Ltd requires disclosure by all employees of any financial
interests or connections, direct or indirect, or other situations which may raise the question
of bias in the work reported or the conclusions, implications, or opinions stated. When
considering whether you should declare a competing interest or connection please
consider the competing interest test: Is there any arrangement that would embarrass
you or any of your co-employees if it was to emerge after publication and you had not
declared it?
If the document is published, this declaration of competing interests’ information may be
communicated in a statement in the published paper. If an employee states that there are no
competing interests then a statement to this effect may be included in the published paper.

Please complete either section I or section II

I. The corresponding employee confirms on behalf of all employees that there have
been no involvements that might raise the question of bias in the work reported or in
the conclusions, implications, or opinions stated:

Printed Name (corresponding employee): Click here to enter text.

Signature:
Date: Click here to enter a date.

OR
II. Conflict of interest statement declared by the corresponding employee on behalf of
all employees:

Example: Drs A & B have received payments and travel funding from [business
name] for overseas lectures. Total funding: approximately [Amount]. Dr C holds
stock in [business name], the makers of [product], and is currently conducting
research sponsored by this company. Dr A is also a member of the speakers’ bureau
for [business name].
The employees’ joint statement is as follows:

Click here to enter text.

Printed Name (corresponding employee): Click here to enter text.

Signature:
Date: Click here to enter a date.

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 TML SOP No: XXXX
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