As part of ADVANZ PHARMA’s continuing commitment to corporate compliance, ADVZ declares that, to the best of its knowledge, and based on a good faith understanding of the statutory requirements of California Health and Safety Code § 119400 and 119402, it has adopted a Comprehensive Compliance Program as mandated by this California law. To the best of our knowledge, as of November 1, 2017, ADVZ believes that it is in compliance with its Comprehensive Compliance Program and its good faith understanding of the requirements of California Health and Safety Code § 119400 and 119402.
Additionally, to comply with California law, ADVZ has established a maximum annual aggregate dollar limit of $1,500 for gifts, promotional materials or activities provided to California health care professionals. This dollar limit represents a spending cap, not a goal or average, and typically the amount spent per physician is anticipated to be substantially less than this maximum amount.
For questions about our Comprehensive Compliance Program or to obtain a copy, please contact us at compliance@advanzpharma.com.
ADVANZ PHARMA is committed to an environment in which open communications are encouraged, including questions or concerns about the compliance program. Employees are required to report any activity or individual that is suspect or in violation of the compliance program. Employees may contact direct managers, the Chief Executive Officer, the Chief Financial Officer, the Compliance Officer or the Compliance Committee at compliance@advanzpharma.com or they may use the Compliance Hotline by calling 855-562-5982. The Hotline is available 24 hours a day/7 days a week to allow confidential and anonymous reporting.
ADVANZ PHARMA has established a Compliance Committee and the committee meets on a quarterly basis. The Compliance Committee is responsible for ensuring the implementation and effectiveness of the Compliance Program, and to provide advice and support to the Compliance Officer.
The Compliance Officer is responsible for overseeing the administration and implementation of ADVANZ PHARMA’s compliance program and will report at least quarterly to the Compliance Committee. The Compliance Officer has authority to direct and implement compliance-related changes and to determine the corporate response to compliance-related matters.
ADVANZ PHARMA policies and procedures were developed to ensure that interactions with healthcare professionals are appropriate, ethical, and consistent with applicable laws and standards. ADVANZ PHARMA expects its employees to comply with the compliance program, its Code of Conduct, policies, procedures, and all applicable laws. Employees must annually acknowledge their responsibility and commitment to conduct ADVANZ PHARMA’s business consistent with these standards and to report to real or suspect violations. Employees who violate these standards are subject to appropriate disciplinary action, up to and including termination. ADVANZ PHARMA’s policies prohibit retaliation against any employee for making a good faith report.
If it is determined that noncompliant conduct has occurred, appropriate parties are responsible for corrective and/or disciplinary actions. ADVANZ PHARMA’s disciplinary actions may include the following: termination; disciplining any involved employee(s); disciplining supervisor for failure to monitor employees appropriately. ADVANZ PHARMA’s corrective and preventative actions may include: revising the compliance program, policies, and/or procedures; revising the role of the Compliance Committee; increased auditing and monitoring; revising the training program.
The compliance program includes activities designed to monitor and audit compliance with ADVANZ PHARMA policies and procedures. The Compliance Officer oversees monitoring and auditing through an audit plan, including internal and external auditing activities. The Compliance Officer works with relevant resources to evaluate audit findings and ensure the implementation of any corrective action. The Compliance Officer (or designee) reviews and evaluates concerns to determine the required investigative response.
As ADVANZ PHARMA evolves as a company and as regulations change, it may amend its compliance program. The Compliance Committee reviews and approves all suggested changes. The Compliance Officer shall be responsible for communicating changes in the compliance program to employees.
For questions about our Comprehensive Compliance Program or to obtain a copy, please contact us at compliance@advanzpharma.com.
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