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Create a code of conduct to establish a culture of compliance

Pharma Compliance Alert, February 6, 2008

Pharmaceutical companies should stress why compliance is the right thing to do when trying to create a culture of compliance, Tom Glavin, Vice President and Deputy Compliance Office for Shire Pharmaceuticals in Wayne, PA, said at last week's Pharmaceutical Marketing and Compliance Congress in Washington, DC.

Glavin added that compliance should be consistent with corporate values and is good for business because it keeps companies on the right side of the law. An effective compliance program can move business objectives forward.

Having a compliance program and having an effective compliance program are not the same, cautioned Steve Kanosky, Associate General Counsel for sanofi-aventis in Bridgewater, NJ, who joined Glavin for the presentation. He added that finding a problem is "not the end of the world." Instead, companies should look at it as an opportunity to make things better.

The OIG requires companies to have a compliance program and makes a code of conduct part of every Corporate Integrity Agreement.

Kanovsky and Glavin offered the following tips to create a corporate code of conduct, including:

• Have a hard copy as well as an electronic version
• Make it readable
• Include an introduction telling people what the code is about
• Keep definitions, terms, and format consistent with other company documents
• Include a Q&A section with typical questions or a chart, list, or table showing what is acceptable and what is not
• Think about getting an outside perspective on your code
• Work with stakeholders when designing the code

Companies should shoot for "a document you want the whole world to see," Glavin said.

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