Transparency International’s UK chapter has released a new online tool to help organisations to combat bribery and corruption.  In an interview for the FCPA blog, Rory Donaldson, Business Integrity Program Manager for TI-UK, stated “the [online] guidance presents international best practice in tackling bribery.”

Sue is delighted to announce that she has signed the Transparency International Declaration Against Corruption.  This is an important declaration in the global fight against corruption, which diverts funds from worthy causes into the pockets of unworthy individuals / groups.

Please show your support by signing the Declaration Against Corruption.

Thanks to Transparency International for adding this tool to their important work.

Now that pharmaceutical companies have disclosed the amounts paid to Healthcare Professionals and Healthcare Organisations by pharmaceutical companies during 2015 in both USA and Europe, it should be very easy for Compliance Officers to spot trends and check whether or not their company is operating in line with others in the industry.  But is it really that simple?

We are conducting analysis and have already noticed several interesting features in the data.  The data must be looked at within the overall context and will need careful interpretation and insights before any conclusions can be drawn or decisions made.

If you would like a copy of our analysis, including our insights into what the data tell us about the industry and individual companies, or you would like us to conduct some specific analysis for you, please do contact us.

As we approach the deadline for pharmaceutical companies to begin capturing information regarding their “Transfers of Value” to Healthcare Professionals and Healthcare Organisations, some companies are struggling to implement consistent data capture processes across their European affiliates.

The EFPIA Disclosure Code has now been transposed into national industry body codes in most countries within EFPIA’s scope.  However, a few countries have yet to fully embrace the EFPIA Disclosure Code, leaving Compliance & Ethics Officers in those countries, and their European leaders, with a difficult dilemma regarding how to comply with both the EFPIA requirements and local requirements.

Some countries (e.g. France, Portugal) already have onerous disclosure requirements that are enshrined in national laws rather than industry body codes, meaning that they apply to all companies regardless of whether or not they have joined their national industry association.  Reporting is already underway in most of these countries with potential criminal sanctions for those companies that get it wrong.

In contrast, those countries that do not have national laws to comply with need to begin data collection from 1st January 2015 for reporting by end June 2016.  If your company has not yet begun to put processes and tools in place to capture these “Transfers of Value”, time is running out for proactive data collection (which will be much easier than retrospective data collection).  Contact us if you need help to get you started.

The first batch of articles from S.E.A.L. Publishing are now available to download from our shop; just follow the links to find them.  There are four Compliance Basics pieces, seven conference reviews, and an article on the use of social media by life science companies in this first batch.  We hope you enjoy the articles and we welcome your feedback.

At a time when global enforcers are focusing their attention on both organisations and individuals, there has never been a better time to ensure that your compliance programme is as robust as possible.  Here are just a few high profile examples from the news during June 2013:

• Walmart replaced its leader in India following bribery probes by local authorities
• A cleric from the Vatican bank was arrested as part of an inquiry into corruption involving allegations that he tried to help friends to transfer money from Switzerland to Italy by plane
• The former treasurer of Spain’s ruling party is being held without bail while he awaits trial for corruption – he is apparently deemed to be a “flight risk” following the transfer of large sums of money from Switzerland to the USA and Uruguay

What do the above cases have in common?  On the face of it, not much.  However, all involve individuals who have allegedly chosen to do the wrong thing while working for large, reputable organisations.  Both their own individual reputations and those of the their employers can be at risk as a result of their actions.  It is only by taking swift, decisive action that large organisations can protect their reputations against the actions of “rogue employees”.  As we all know, prevention is much better than cure, so did these large organisations have adequate prevention and detection mechanisms in place, or did they believe that it couldn’t happen to them?

What about your organisation?