Otoplug Oy Code of conduct

Interaction with people is at the core of our business. This Code of Conduct provides guidance to all Otoplug Oy´s employees, and to our customers, suppliers, owners, and all other stakeholders.

The Code of Conduct covers Laws & Regulations, Stakeholder Interactions, Environmental Health & Safety, and Reporting as they apply to our business. It is considered the compliance standard for the entire Otoplug Oy.

Laws & Regulations

Respect the law

At Otoplug Oy, our employees must adhere to all laws and regulations of the countries where they do business. Employees are expected to know the required laws and regulations that apply to their job and position.

Laws and regulations differ from country to country. In case of conflicts between the principles in this code of conduct and local laws and regulations, the local laws and regulations shall prevail. If you have questions, ask your manager.

Antitrust and Competition

It is prohibited to have agreements between Otoplug and our competitors that can affect prices, terms of conditions of sales, and fair competition. Being responsible for a business area you may not enter into any agreement that violates free trade.

It is prohibited to contact competitors about pricing, costs, or terms of conditions of sale. Discussions with distributers or customers that unfairly restrict trade or exclude competitors from marketplace are not allowed.

We follow all applicable laws and regulations concerning Antitrust and Competition and we are aware that laws differ from country to country. Therefore, local legal authorities may be contacted to ensure local compliance.

Bribery, Fraud and Corruption

All business relations shall be according to local laws and regulations and conducted in a professional and honest way. Otoplug employees shall never offer or accept inappropriate items of value, including gifts or entertainment. Any form of bribery, fraud, corruption, or wrongdoings, such as for example extra payments or financial benefits, are strictly forbidden.

We will not offer or make illegal payments to government officials or any business partners, directly or through intermediaries.

Giving Gifts & Entertainment

Gifts or entertainment may be given only where appropriate and where there is no risk of creating the perception of influencing the recipient in his/her decision.

Gifts must be of minimal value and entertainment must not go beyond what is reasonable. Lavish or inappropriate gifts or entertainment are strictly prohibited. Maximum gift value is set to under 100 €.

Otoplug does not give present on the behalf of third-party stakeholders or suppliers.

Stakeholder Interaction

Business relations

Otoplug´ s business relations shall be handled with respect for all parties such as patients, healthcare professionals, governments, regulatory entities, customers, hospitals, suppliers, and other stakeholders. We will be honest and fair in all our business dealings.

All employees at Otoplug Oy must act in a professional, ethical way and according to local laws and regulations for the business in each country. We will gather and handle all customer data and business intelligence appropriately following local laws.

Demonstration products policy (Demos)

Demonstration products and/or samples may be either single or multiple-use products. Provision of demonstration products and/or samples must not improperly reward, induce and/or encourage healthcare professionals and/or healthcare organizations to purchase, lease, recommend, prescribe, use, supply or procure products or services.

Otoplug may provide examples of their products to Healthcare Professionals and/or Healthcare organizations in the form of mock-ups (such as unsterilized single use products) that are used for Healthcare Professionals and patient awareness, education, and training.

People and Employment

We abide by all working regulations, laws, and union agreements (when applicable) in all countries where we are present. Otoplug follows strictly the requirements concerning social taxes, insurances, and other mandatory conditions for employments. We treat our employees and job applicants with respect and fairness.

Discrimination or Harassment

We shall show respect to our colleagues and business partners. The working environment for all Otoplug employees must be free of emotional, verbal, or physical harassment. This includes any comments or actions regarding race, color, ethnicity, religion, gender, sexual orientation, age, mental or physical disability, medical conditions, or any other characteristics protected by applicable laws.

Environmental Health & Safety

Health and Safety

Otoplug shall strive for a good and healthy working environment for its employees and consultants, to minimize health and safety risks in the working place. We comply with all healthcare laws and regulatory requirements applicable to our industry. We shall ensure that employees have all the working tools, safety equipment and education needed for their function. Any abuse of drugs and alcohol can pose serious health and safety hazards in the workplace or in any business-related situation. To secure a safe working environment it is forbidden to use any drugs or alcohol within the workplace and during working hours. When alcohol is consumed while entertaining and representing the company it should only be offered and consumed moderately and with responsibility.


Our environmental policy is the responsibility of all employees and is available to suppliers, customers, and other stakeholders. In collaboration with customers, suppliers, and partners we develop our business and strive to reduce consumption of energy and raw materials as well as reducing emissions.


We are committed to develop, maintain, and supply high quality products. Our procedures follow all relevant laws, regulations, and applicable guidelines in the markets in which we are represented.


Financial reporting and inquiry

All financial reporting, books, records, and accounts for the Otoplug must be accurate and correct. We safeguard all business records, and we shall fulfill our obligation to provide accurate financial and other disclosures as stipulated to the local public, governments, and investors. These include financial statements, invoices, expense reports, payroll and benefits records, and other essential company data.

Travel Expense Policy

It is the policy of Otoplug Oy to reimburse staff for reasonable and necessary expenses incurred during approved work-related travel.

Employees seeking reimbursement should incur the lowest reasonable travel expenses and exercise care to avoid impropriety or the appearance of impropriety. Reimbursement is allowed only when reimbursement has not been, and will not be, received from other sources. If a circumstance arises that is not specifically covered in this travel policy, then the most conservative course of action should be taken.

Reporting a concern

Adherence to the principles in the Code of Conduct is a requirement of being a part of Otoplug Oy. These principles are not exhaustive but address the essential areas. We encourage employees to discuss or address issues of concern with their manager. If someone appears to violate the law or policy, in the first instance notify your manager. If you are uncomfortable approaching your manager, you may contact the CEO. It is essential that all staff feel comfortable to raise compliance concerns. Any concerns that are raised will be anonymous and treated in the strictest confidence. Retaliation against any colleague who seeks advice, raises a concern, or reports misconduct is strictly forbidden. All reported concerns will be taken seriously, investigated, and appropriate action will be taken.