With the aim of ensuring that the public and companies can always have full confidence in the Icelandic Medicines Agency, the Agency has adopted the following Code of Conduct.

The Code of Conduct applies to all staff of the Icelandic Medicines Agency.

The Code of Conduct is based on the general code of conduct for government employees, issued on the basis of the Act on the Rights and Obligations of Government Employees No. 70/1996. The Code of Conduct is also based on provisions of the Medicinal Products Act No. 100/2020 and the Veterinary Medicinal Products Act No. 14/2022, which state, among other things, that neither the Executive Director nor other staff of the Icelandic Medicines Agency may have special and significant interests in the development, manufacture, marketing, importation, brokerage, wholesale distribution or retail sale of medicinal products. The Code of Conduct also takes account of the codes of conduct of professional groups, as applicable in each case, and the Act on the Protection of Whistleblowers No. 40/2020. Further guidance may be provided in other and more specialised policies and procedures of the Agency. The Administrative Procedures Act No. 37/1993 also imposes certain obligations on staff regarding proper conduct in their work, such as provisions on an employee’s competence to handle a matter, proportionality and ensuring that considerations of equality are always observed. The Code of Conduct reflects the values of the Icelandic Medicines Agency, which are Quality, Trust and Service.

Conflicts of interest and gifts

• Staff disclose, at least annually, any interests that may give rise to conflicts of interest and do not undertake secondary employment, positions of trust or association activities that are incompatible with their work at the Icelandic Medicines Agency.

• Staff who intend, alongside their work, to undertake paid employment, join the board of a business undertaking or establish a business must inform the Executive Director of their intention in advance.

• Staff avoid conflicts between the public interest, on the one hand, and their own financial or personal interests or those of related parties, on the other, and do not use their position or information obtained through their work for their own benefit or for the benefit of related parties.

• Staff exercise moderation in accepting gifts and follow the Icelandic Medicines Agency’s procedure on gifts and invitations to staff.

Cost awareness and environmental awareness

• Staff exercise prudence in the handling of the Icelandic Medicines Agency’s funds. Expenses are not incurred on behalf of the Icelandic Medicines Agency unless their purpose is consistent with the Agency’s activities and role.

• Staff do not use public funds or work-related resources for personal purposes or to favour others.

• Staff treat nature with respect and take account of environmental impact and the Agency’s green steps in procurement and daily work.

Conduct and behaviour

• Staff communicate carefully and act with courtesy and respect, ensuring that they are objective and fair in opinions, feedback and comments about others within the Agency.

• Staff respect confidentiality towards colleagues and the workplace, including when using social media.

• Staff adopt working methods that can create trust in their work and in the Agency, and respect human rights and human dignity.

• Professionalism, cooperation and mutual respect characterise the working environment of the Icelandic Medicines Agency.

• Staff acknowledge mistakes and seek to learn from them.

Professional working practices

• Staff uphold democratic values, maintain the highest level of professionalism and demonstrate political neutrality.

• Staff must familiarise themselves thoroughly with the laws, rules and standards applicable to the Agency’s activities. All matters must be clearly recorded, and matters that are demonstrably outside the remit of the Icelandic Medicines Agency must be referred to the appropriate body.

• Staff take care in their working methods and in all handling of information and data, and observe confidentiality and data protection.

• Staff base their advice and decisions on the best available information. Expert professional assessments are obtained where appropriate.

• Staff make efforts to maintain and improve knowledge in their field of work.

• When staff make decisions, they must ensure that there is consistency between the decision made and the objective pursued, and observe proportionality in accordance with the proportionality principle of the Administrative Procedures Act. In particular, staff must avoid restricting the rights of customers where the proposed measures are not reasonably connected to the purpose of those measures. A fair balance between the interests of individuals and the public must be kept in mind.

Transparency and information sharing

• Information is provided readily in accordance with law and general standards.

• Staff communicate information accurately, honestly and clearly.

• Mistakes or misunderstandings relating to decisions, the handling of matters or the communication of information are corrected as soon as possible.

• Staff seek to maintain accessible and open communication with the public and stakeholders.

Responsibility and follow-up

• Each staff member, in accordance with their position and role, is responsible for their actions and conduct and, for their part, ensures that this Code of Conduct is followed.

• Managers must ensure that staff are familiar with the rules and that they are a natural part of the work of the Icelandic Medicines Agency, respond when they are not followed and lead by good example.

• In cases of doubt that may arise, staff may always consult their immediate supervisor, division head, Human Resources Manager or Executive Director, as applicable, and seek advice or an opinion.

• If staff become aware of ethically reprehensible or unlawful conduct in the workplace, they must report it to their immediate supervisor, division head, Human Resources Manager or Executive Director, as applicable, while avoiding reporting it to a person who is involved in the matter.

• Staff do not suffer consequences for reporting breaches of the Code of Conduct, laws or regulations, or for seeking to enforce their rights if they believe that their rights have been violated.

This Code of Conduct was approved by the Executive Board of the Icelandic Medicines Agency on 4 March 2025.