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Governance & Ethics
Statement on Responsible Interaction with Health Care Professionals

Ethical relationships with health care professionals are a critical part of developing and marketing health care products.

Physicians need to learn how to use new medicines and medical devices. Company representatives have an important role in teaching them about these products.

People expect the care they receive to be based on their individual needs and the medical knowledge and experience of their doctors. We are committed to protecting the doctor’s medical judgment and treatment choices from improper influences so that the patient’s needs come first.

To help ensure the integrity of the relationship between our representatives and doctors, our policies and guidelines are based on industry codes of conduct as well as the legal, regulatory and professional requirements of the countries where we do business. Among these are:

  • U.S. Federal Anti-Kickback statute that prohibits improper influence in health care decision-making by making it a crime to knowingly and willfully offer, give or receive anything of value in order to influence or obtain government health care business.
  • U.S. Federal False Claims Act that prohibits making or inducing someone else to make a false claim for reimbursement from the federal government.
  • U.S. Federal Food, Drug and Cosmetic Act and FDA Regulations that authorize the U.S. Food and Drug Administration (FDA) to regulate many aspects of our business, from research and development to advertising and promotion of our products.
  • U.S. Foreign Corrupt Practices Act (FCPA), which makes it unlawful for a US person or a US company to give or offer anything of value (directly or indirectly) to a non-US government official to influence any act or decision by that official for the purpose of obtaining or retaining business.
  • Compliance and disclosure laws and industry codes restricting or requiring public reporting about payments and other transfers of value made to health care professionals. These include the Physician Payments Sunshine Act (commonly known as "Sunshine Act" or "Open Payments"), part of the Patient Protection and Affordable Care Act and the Code on Disclosure of Transfers of Value from Pharmaceutical Companies to Healthcare Professionals and Healthcare Organisations, adopted by the European Federation of Pharmaceutical Industries and Associations (commonly known as the EFPIA Disclosure Code).
  • Country laws governing the advertising and promotion of medicinal products and medical devices; Country laws governing the public tender process; Country laws governing fair competition/anti-trust issues.
  • Industry Codes that aim to protect medical decision-making from improper financial incentives and govern companies’ policies on gift giving, grants and other funding.

Our standards and requirements are consistent with Our Credo, and based on laws, regulations and industry codes that apply to our business conduct with stakeholders.

Last Updated: January 2017

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