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inVentiv Health is committed to conducting business with integrity and preserving a culture of high ethical principles and professional standards. To demonstrate our commitment, we have established a Corporate Compliance Program that conforms to the principles and physical requirements published in the Office of Inspector General, U.S. Department of Health and Human Services "Compliance Program Guidance for Pharmaceutical Manufacturers." |
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inVentiv recognizes maintaining a successful program depends on employees upholding our cultural beliefs and conducting business in accordance with our Code of Business Conduct and Ethics, company policies and procedures, and all applicable laws, regulations, and industry guidelines. Our corporate compliance program includes the following elements: |
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Written Policies and Procedures |
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Corporate Compliance Officer and Compliance Committee |
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Effective Training and Education |
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Effective Lines of Communication |
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Internal Monitoring and Auditing |
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Enforcement through Discipline in Pursuant to Published Guidelines |
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Prompt Response and Corrective Action for Detected Problems |
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Corporate Policies and Procedures |
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inVentiv has established corporate standards to guide and govern the conduct of all employees, officers, directors, consultants, contractors and other company representatives to ensure their actions on behalf of the Company are honest, ethical, lawful and beyond reproach. These standards also establish conditions for employment at inVentiv and procedures for detecting and reporting illegal or unethical behavior. All inVentiv employees are required to annually acknowledge their responsibility and commitment to conduct company business in compliance with applicable laws, regulations, industry guidelines, and company policies. Additionally, to encourage the use of internal controls to effectively monitor adherence to applicable laws, regulations and other industry guidelines, inVentiv’s four core business segments: inVentiv Clinical, inVentiv Communications, inVentiv Commercial, and inVentiv Patient Outcomes have implemented written policies and procedures that describe acceptable business practices, specific to their business.
Company policies and procedures are made available through employee handbooks, company websites, and inVentiv’s core business segments. |
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Corporate Compliance Officer and Corporate Compliance Committee |
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inVentiv’s Corporate Compliance Program operates under the direction of our Chief Compliance Officer, who reports directly into the COO of inVentiv Health. The Chief Compliance Officer also chairs the Corporate Compliance Committee which is comprised of compliance specialists from inVentiv’s four core business segments. The Chief Compliance Officer has authority to report compliance matters directly to inVentiv’s CEO, President and COO. The Corporate Compliance Committee has direct access to senior executives who have the authority to implement compliance-related change within their respective business segment. |
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Training and Education |
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An important element of our Corporate Compliance Program is the training and education of our employees. inVentiv Health has implemented training programs to educate employees on their obligation to comply with company policies and procedures and with all applicable laws, regulations and industry guidelines.
In addition, business units within inVentiv’s core business segments have implemented training programs to educate employees on the standards and procedures specific to their job functions. The Corporate Compliance Committee evaluates inVentiv’s training needs and implements corporate training programs for all employees on an as needed basis.
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Effective Lines of Communication |
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inVentiv adheres to an “Open Door Policy,” and encourages employees to discuss issues and/or concerns of misconduct with their manager or other senior personnel, Human Resources or a member of the Corporate Compliance Committee. Other avenues made available to employees include:
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Corporate Compliance Anonymous Hotline
inVentiv’s Corporate Compliance Hotline is available 24 hours a day 7 days a week. Employees access the hotline by calling 800-673-7309. |
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Corporate Compliance Anonymous Allegation Website
Much like the Corporate Compliance Hotline, our Corporate Compliance Website allows employees to report issues or concerns of misconduct while having a choice to remain anonymous. Employees can access the website at:
https://www.compliance-helpline.com/inVentivHealth.jsp |
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Communication to the Audit Committee
inVentiv’s Audit Committee maintains procedures for the receipt, retention, and treatment of complaints regarding accounting, internal accounting controls and auditing matters. The Audit Committee is readily accessible thru the Director of Internal Audit. |
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Chief Compliance Officer and Corporate Compliance Committee
inVentiv’s Chief Compliance Officer and members of the Corporate Compliance Committee are readily accessible to all employees seeking compliance information and or guidance. Committee includes:
Chief Compliance Officer
Compliance Specialist/Privacy Officer, Patient Outcomes
Compliance Specialist, Clinical Solutions
Compliance Specialist, Communications
Compliance Specialist, Commercial
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Monitoring, Auditing and Investigations |
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The Chief Compliance Officer will review and evaluate all concerns, questions or allegations reported through the Corporate Compliance Program to determine the need for further investigation. The Chief Compliance Officer may request assistance from members of Human Resources and/or members of the Corporate Compliance Committee to conduct investigations on matters related to their respective business segments. The Chief Compliance Officer will evaluate all audit findings and if necessary, will collaborate with Human Resources to ensure corrective action occurs in a timely manner.
Individual business units within inVentiv’s core business segments are also responsible for implementing procedures to monitor and audit compliance with their policies and procedures to detect and correct potential compliance issues before they occur. |
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Enforcement through Discipline in Pursuant to Published Guidelines |
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inVentiv Health has well-publicized disciplinary guidelines in place to educate employees about the company’s commitment to compliance. All employees are informed that failure to adhere to company policies and procedures may include disciplinary consequences, up to and including termination of employment. All policy violations are reviewed on a case-by-case basis and a thorough investigation is conducted before disciplinary action occurs. To the greatest extent possible, all investigations will be conducted confidentially. |
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Prompt Response and Corrective Action for Detected Problems |
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inVentiv Health has various mechanisms in place to detect violations of law or company policies and procedures. It is expected that compliance issues referred through any of the communication channels (personal contact, e-mail, anonymous fax, compliance hotline or website, etc.) will be carefully reviewed, thoroughly investigated and resolved in a timely manner.
For a written copy of this inVentiv Health Corporate Compliance Program,
call 732-584-5379.
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Declaration of Compliance |
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Based upon our good faith understanding of the California requirements, and to the best of our knowledge, we hereby declare that as of the date of this declaration, inVentiv Health is compliant with this comprehensive compliance program as required by the California Health and Safety Code 119400-119402. inVentiv Health is committed to conducting business in accordance with the highest ethical principals and all applicable laws and regulations, thus when appropriate, will amend and update our policies, and this statement to assure compliance with the law. |
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For more information contact Tricia Glover, Chief Compliance Officer
tglover@inventivhealth.com |
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