Compliance processes
Our guiding light
Compliance is at the heart of Third Bridge. Whether onboarding a new specialist, facilitating a consultation or conducting a Forum Interview, our actions are guided by our Code of Ethics and compliance policies.
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Our Approach
Compliance components
Our compliance programme is based on three pillars, centered on obtaining confidentiality agreements, education and training, and screening.
The three pillars
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Obtaining agreements from specialists
- Our clients and specialists agree that confidential information (including material non-public information) must not be solicited or disclosed during an interaction
- Specialists agree that a consultation must not breach contractual, fiduciary or other legal obligations to which they are subject
- They must also agree that clients’ identity and any information shared by them will remain confidential
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Education and training
- All specialists are trained on their compliance obligations. Offered in nine languages, our compliance tutorial covers:
- Market abuse and insider trading – what constitutes material non-public information (MNPI), why it is illegal to provide or solicit MNPI or act upon it, and why it would be detrimental for clients to receive it
- Duties of confidentiality
- Anti-bribery and corruption rules
- Identifying when a consultation would breach their obligations under contract or general law
- Forum specialists are also briefed on the Interview agenda and any topics that the specialist thinks should be excluded
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Screening
- Specialists should not speak about their current employer, and for Forum Interviews they must be six months removed from any affiliation with the company in question to participate
- Restrictions are imposed upon specialists who are involved in or have access to data from unpublished clinical trials
- Restrictions are imposed upon specialists who are currently elected official or employed by a government entity
- Additional restrictions can be applied on an ad-hoc basis
Sourcing specialists
How we find specialists
Once a specialist is identified, we assess whether they have the requisite expertise and are willing and able to consult with our clients. After this, they will complete our standard compliance steps.
Our approach
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Leveraging existing relationships with industry professionals
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Using publicly-available sources or databases
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Obtaining referrals from existing contacts
Due diligence
Background checks on prospective specialists
Background checks are a fundamental element of compliance. To ensure specialists are who the say they are, we do the following:
Core considerations
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Refuse unsolicited requests from experts
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Ask specialists to sign Terms & Conditions
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Screen specialists via our proprietary FactShield™ tool
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Specialists provide biographical information and confirm its accuracy
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Obtain confirmation that specialists have not been found guilty of, or sentenced for, insider dealing, market abuse, money laundering or similar offences in any jurisdiction
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Screen our specialists database weekly against sanctions lists
Limitations
Working with particular types of specialists
There are no limitations on specialists currently employed by public companies, unless requested by a client.
Working with particular types of specialists
Third Bridge Forum
Third Bridge Forum
In addition to all the compliance steps we take across the Connections service, Third Bridge Forum enforces stringent policies and procedures to prevent confidential or material non-public information being disclosed during an Interview. In order to do this, we take the following steps:
The Interview approval process
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Specialists must agree to Forum's Terms of Engagement and Compliance
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Specialists must not be a government employee
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A third-party criminal background screen is completed on each specialist
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Specialists must agree not to speak about their current employer
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Specialists must not have been involved in any clinical trials or have access to non-published clinical data on the Internet topic
The transcript review phase
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Checking that no material non-public information or confidential information were disclosed
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Ensuring no investment advice was given
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Ensuring no defamatory or derogatory comments were made
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Developing policies and procedures to govern the transcript review process, including procedure and escalation protocols
Employee Training
Third Bridge approach and policies
Third Bridge employees complete two sessions of compliance training within their first week of joining.
Compliance training
FAQs
Common questions
Please contact us if you have any other questions.
FAQs
If we are notified that a company does not allow its employees to participate in outside consultations, we add that company to our do-not-contact (DNC) list. IT blocks and warnings ensure that no one employed at a company on the DNC list consults on client projects.
If an issue regarding inappropriate conduct is raised by the client or specialist, the matter must immediately be reported to Third Bridge Legal and Compliance. An investigation is then initiated and we work with the client’s compliance team to resolve the matter. If necessary, we would take appropriate action based on the results.
If you believe you have been asked for improper information during a consultation with one of our clients, please refuse to answer the question. If the improper questions persist, please end the consultation and contact Third Bridge immediately. Your compensation will not be affected if you have ended a consultation due a compliance concern.
Specialists are paid at a rate agreed upon prior to participating in any consultation or Forum Interview. Forum Specialist compensation is not affected by the number of clients that join a live Interview or download the transcript. If a specialist ends a call early for compliance reasons they will still be paid for their actual time engaged, plus an additional 15 minutes.
No. Third Bridge does not participate in, or record, calls between specialists and clients. In our view, telephone consultations between clients and specialists are confidential and we do not have the right to record and monitor them. We offer a separate service to transcribe Connections consultations, with certain restrictions and limitations.
Yes. Clients may log into our compliance portal and approve all or some of their Connections consultations.
Yes. We can provide usage reports at a frequency determined by the client (e.g. quarterly, monthly, weekly).
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