Monitoring compliance

We have monitoring processes in place worldwide to identify any breaches of our policies. These include:

  • Our internal audit and monitoring processes: We have central teams dedicated to supporting and delivering monitoring and auditing at our sites locally. Line sales managers monitor the activities of our sales representatives. We have a nominated signatory in each country to approve all marketing material before release. Local compliance officers support line managers, ensure that adequate processes and training are in place and conduct independent monitoring of activities that raise the highest risks. In the US, home to our largest sales force, we have compliance leaders assigned to support each sales region and each brand marketing team.
  • AZethics - Our ethics helpline is available for any employee, healthcare professional or member of the public to report suspected breaches of our policies, anonymously if local laws permit. The helpline is promoted on our website and run by an independent company on our behalf. Employees can also use the helpline for advice and guidance on any issues they come across in their work.

    Healthcare professionals and other pharmaceutical companies can also report issues to regulators or the relevant national code of practice body, for example the Prescription Medicines Code of Practice Authority (PMCPA) in the UK and Food and Drug Administration (FDA) in the US.

    External reviews: We continue to commission external reviews of our sales and marketing activities by specialised auditors. These may involve particular countries and/or particular aspects of marketing practices. These external reviews provide valuable insight into areas where we might improve our compliance.

What actions do you take when you find a problem?

The action we take will depend on the type of breach identified, but may include guidance and coaching and disciplinary action up to and including dismissal. Where appropriate, we may also revise our policies and supplement our training with further case studies to make sure our requirements are fully understood.

Outside the US, serious breaches identified by our sales managers and local compliance officers are reported to our Regional Compliance Vice President and Regional Executive Vice President. In the US, our US Compliance Officer chairs the compliance committee that reviews a summary of compliance findings quarterly.

It is important that we understand why a breach has occurred and how we can prevent a reoccurrence. Any serious breaches identified may be shared with our Global Compliance Leadership Team to ensure that lessons learned are captured in the relevant parts of the business. Our Chief Compliance Officer reports serious cases to the Audit Committee of our Board four times a year. We also publish a high-level global summary of compliance incidents and the resulting disciplinary action on our internal website every six months.

We now publicly report the global number of commercial employees involved in disciplinary actions during the year, including the number of associated dismissals. This information provides the broader context of our internal governance and the number of actions taken in relation to breaches of external or internal sales and marketing codes. It also reinforces for our employees and other stakeholders how seriously we take breaches of our policies.
 

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