Life Science Compliance Update

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February 17, 2017

Anti-corruption: All roads lead to enforcement


When it comes to corruption, Life Sciences companies are a frequent target of investigation and enforcement. The French enactment of Sapin II is the latest in a long line of laws to combat corruption. This article explores Sapin II and why the authors feel that Life Sciences companies are among the best positioned to comply with Sapin II’s requirements.

Corruption occurs across all industries – from banking and finance to energy and mining – however, Life Sciences companies are frequently under the microscope due to a variety of circumstances unique to the industry. Among these circumstances are the fact that:

  1. Customers and influencers of prescription drug use are often public officials (i.e. HCPs can be government employees or work at public institutions),

  2. Company-sponsored event objectives can be unclear (i.e. whether a sponsored event or engagement is related to scientific exchange or is promotional/ commercial in nature),

  3. There is a heavy reliance on third parties and sub- contractors who are responsible for engaging with government officials and employees, and relatedly, and

  4.  Complex supply chains and distribution channels typically span all corners of the globe.

    Read the full article in the February 2017 issue of Life Science Compliance Update

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