Business Ethics and Compliance

Every modern company seeks that its business should comply with legislation and business ethics. Both Ukrainian legislation and international legal norms require transparent and ethical business conduct. For pharmaceutical companies compliance with legislation on prevention and combating corruption long ago became an integral part of business, important part of internal processes, policies and procedures. Our practice “Anticorruption Ethics and Compliance” fruitfully deals with this issue.

We are developing and introducing anticorruption compliance programs, including policies, operation procedures, action algorithms, professional ethics codes, personnel training programs, internal corruption investigation procedures, and monitoring of effectiveness of work with contractors and intermediaries.

We consult clients on issues of Ukrainian anticorruption legislation and direct and indirect influence on Ukrainian and CIS residents of the Foreign Corrupt Practices Act - FCPA, 1977, UK Bribery Act 2011 and respective acts of EU member-states.

SERVICES

Internal policies, procedures, instructions

• Verification and adaptation (if needed - development) of internal policies, operational procedures, rules and instructions for compliance with anticorruption legislation and corporate requirements;
• Analysis of marketing activities schemes for compliance with anticorruption legislation;
• Development of anticorruption programs and promotional programs.

Anticorruption Due Diligence

• Development of policy for verification of contractors and document forms for contractor verification;
• Contractor verification;
• Preparation of official opinions upon contractor verification.

Internal investigation

• Internal investigations of violations of anticorruption legislation and corporate company policies.

Standard documents

• Development of standard anticorruption reservations in agreements with contractors and anticorruption regulations to job instructions;
• Development of standard agreements (correspondence) with contractors on sponsorship, charity, and service agreements.

Personnel training

• Internal workshops and seminars on certain topics;
• Development of memory notes and practical guidelines for employees.

Control system

• Development of procedure for employee questioning, reporting, forms of questionnaires and periodic reports.

Compliance officer

• Development of job instruction for “Person Responsible for Compliance with Anticorruption Legislation”;
• Consulting of the responsible person on current activities.

EXPERIENCE

• Full set of policies and SOPs, and standard documents developed, workshop conducted, and also introduction of Compliance system “from the scratch” for a subordinated company accompanied.
• Mechanism of compliance verification of contractors for a company leader on the pharmaceutical market arranged and introduced.
• Corporate policy for charity support and sponsorship for a representative office of a pharmaceutical company developed.
• Policies on promotion of OTC medicines for a representative office of a pharmaceutical company world leader for development and production of OTC medicines developed.
• Full set of policies of transnational pharmaceutical corporation adjusted to Ukrainian legislation.
• Standard form of healthcare professional consent and standard provisions for inclusion to agreements on information disclosure and fulfilment of EFPIA developed for a representative office of a Japanese pharmaceutical company.
• Policies and procedures for promotion of vet medicines for vet department of a European pharmaceutical company adjusted.
• Requirements of the Global Policy on admissibility of invitations, gifts and other advantages provided to company employees by third parties implemented to local policies for a representative office of a German pharmaceutical company.
• Standard chapters on anticorruption issues to be included in agreements, labour contracts and job instructions developed.
• Workshops for personnel on changes to anticorruption legislation, local policies and codes for representative offices of 12 international pharmaceutical companies conducted.