Valeant has established and oversees an effective and comprehensive compliance program in accordance with federal, state, and industry guidelines including the "Compliance Program Guidance for Pharmaceutical Manufacturers", published by the Office of the Inspector General (OIG), U.S. Department of Health and Human Services and the Pharmaceutical Research and Manufacturers of America's (PhRMA) "Code of Interactions with Healthcare Professionals" .
Valeant's Compliance Program is designed specifically to meet the unique needs of our Company, which includes ensuring that Valeant meets the obligations set forth under our Corporate Integrity Agreement ("CIA") with the OIG. There has been a significant amount of effort that has been dedicated to implementing a comprehensive compliance program at Valeant including checks and balances to prevent and detect violations of law or Company policy.
Key elements of the Valeant Compliance Program include:
- The appointment of a Chief Compliance Officer.
- A fully functioning Risk and Compliance Committee of Valeant's Board of Directors.
- A Code of Conduct that promotes the highest ethical standards and behaviors for business practices.
- A Code of Professional Conduct for Senior Finance Executives to ensure the highest ethical standards in the area of financial management.
- Extensive policies and procedures contained in the Healthcare Compliance Manual.
- A variety of training and educational activities offered through many mediums.
- Targeted auditing and monitoring of business activities.
- Anonymous reporting along with other communication mechanisms to raise compliance concerns.
- Well-publicized disciplinary guidelines.
Valeant is committed to the maintenance and ongoing assessment necessary to ensure an effective Compliance Program.
In addition, and in compliance with its CIA, Valeant supports the government's role in enhancing transparency of payments made to U.S. Health Care Professionals and grants and donations given to U.S. Health Care institutions and physicians by posting details of all such payments and grants.