Concordia International Corp. (“Concordia” or “CIC”) is committed to conducting its business ethically and in compliance with all applicable laws, regulations, guidelines, and policies. Concordia has established and implemented a Code of Conduct (“The Code”), which sets forth CIC’s commitment to ethical business conduct.
The Compliance Officer is responsible for overseeing the administration and implementation of Concordia’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.
Concordia 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.
Concordia policies and procedures were developed to ensure that interactions with healthcare professionals are appropriate, ethical, and consistent with applicable laws and standards. Concordia 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 Concordia’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. Concordia’s policies prohibit retaliation against any employee for making a good faith report.
Communicating Compliance Issues and Concerns
Concordia 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 email@example.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.
Monitoring, Auditing, and Investigations
The compliance program includes activities designed to monitor and audit compliance with Concordia’s 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.
Corrective Action and Discipline
If it is determined that noncompliant conduct has occurred, appropriate parties are responsible for corrective and/or disciplinary actions. Concordia’s disciplinary actions may include the following: termination; disciplining any involved employee(s); disciplining supervisor for failure to monitor employees appropriately. Concordia’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.
Updating the Compliance Program
As Concordia 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.
CALIFORNIA COMPLIANCE LAW DECLARATION
As part of Concordia’s continuing commitment to corporate compliance, CIC 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 September 1, 2018, CIC 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, CIC 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 firstname.lastname@example.org.