Firewall Requirements Genentech prohibits grant requestors and their educational partners (e.g. third party providers) from performing promotional activities for Genentech while also contributing to, providing or accrediting independent medical education (IME) funded in whole or part by Genentech, unless there is sufficient separation (firewalls) between the grant requestor's or partner's promotional and medical education business units.

Before a grant request is considered, the grant requestor must certify to Genentech that it and all its educational partners possess and adhere to a firewall policy that is in compliance with Genentech's firewall criteria, an overview of which may be found below. All requestors must complete a Firewall Certification Form when registering online with IMED's Grant Management Application (GMA) and must re-certify compliance annually.

Firewall Criteria

• Separate Employees/Contractors
• Separate Legal Entity
• Separation of promotional/IME information and content, including, but not limited to, prohibition on sharing substantive information, physical separation of functions, and information technology (IT) safeguards
• Compliance training and audits
• Monitoring of compliance policies and corrective action