Responsibility
Objectives
Camurus works to ensure a high level of business ethics in all dealings with suppliers, healthcare professionals, patients, third parties and other stakeholders. Our ambition is to proactively work to prevent corruption, anti-competitive behavior, and bribery throughout our entire value chain. We strive to always conduct our business and interact with stakeholders in an ethical, responsible and respectful manner.
Camurus has established a corporate Ethics & Compliance Framework, with the objective to promote compliance with all applicable laws and regulations, industry codes, company policies and procedures. The aim is to foster a culture embracing integrity and ethical behavior, in all our businesses. Furthermore, the framework includes mechanisms for the risk assessment and prevention of compliance issues, and the identification, reporting, investigation and correction of misconduct.
Governing documents
Camurus’ corporate values and company Code of Conduct set the foundation of this framework, which is accompanied by a number of governing documents, such as company policies and procedures implemented at a global and/or local level that apply to Camurus’ business in the United States. These include, among other things, the Anti-Corruption Policy, Camurus’ program for Third-Party Risk Management, Data Protection Policy, Sustainability Policy, Healthcare Interactions Policy and Healthcare Compliance Standard Operating Procedure (SOP). Camurus’ corporate policies can be found at Camurus’ global corporate website
Managing the ethics compliance framework
The Ethics & Compliance Framework is managed by the appointed Compliance Officer, reporting to the company’s CEO, and is overseen by the Board. The continuous duty to uphold and develop the framework, is further supported by e.g., local compliance resources, management, and the Compliance Committee structure. A full-time Legal & Compliance Counsel, reporting to the President of Camurus Inc, has been assigned to manage business ethics and compliance at the US level.
All employees receive comprehensive training as part of their onboarding with Camurus. Regular training refreshers and additional in-depth compliance training for personnel, is part of the compliance training program managed by the Compliance Officer.
Healthcare compliance
With regards to our interactions with the healthcare community, Camurus’ Ethic & Compliance Framework is designed to ensure compliance with applicable laws, regulations, and industry codes.
Although not a member of the Pharmaceutical Research and Manufacturers of America (“PhRMA”), Camurus supports and has implemented policies and procedures that are consistent with the requirements of the PhRMA Code on Interactions with Healthcare Professionals originally published on 1 July, 2002, and last revised as of January 2022 (the “PhRMA Code”).
Our healthcare compliance program is designed to ensure that all interactions with healthcare stakeholders (such as physicians, hospitals, patients, caregivers, etc.) are permeated by responsibility, and that no illegal or unfair activities take place, such as false or misleading product information, pre-approval or off-label promotion, or bribery (e.g. provision of excessive hospitality, gifts or entertainment).
Consistent with guidance found in the Compliance Program Guidance for Pharmaceutical Manufacturers issued in 2003 by the Office of the Inspector General of the Department of Health and Human Services (“OIG Guidance”), Camurus has designed its healthcare compliance program to fit the size, resources, and other unique aspects of our organization. Camurus also recognizes that an effective compliance program must evolve and respond to the changing circumstances of the organization and the compliance, legal and regulatory environment.
Auditing and monitoring
To measure the efficacy of Camurus’ training and education program, as well as to confirm that Camurus personnel and contractors are acting in an expected compliant manner, Camurus will periodically perform monitoring activities and conduct audits to evaluate compliance with company policies and applicable laws. The nature, frequency and extent of these reviews may vary according to factors such as internal risk assessments, regulatory requirements and developments, and changes in Camurus’ business practices.
Incident reporting and compliance investigations
All employees are required to report any suspected misconduct through one of the mechanisms set out in Camurus’ company policies. This includes anonymous reporting through Camurus’ dedicated whistleblowing platform available on Camurus’ corporate websites (see link below). Camurus also encourages any third-party (e.g. vendors, suppliers, business partners, agents, job applicants etc.) to raise any concerns related to suspected misconduct involving Camurus’ business via the platform. Camurus is firmly committed to addressing all alleged misconduct brought to our attention in a timely fashion.