Galderma Laboratories, L.P. is committed to conducting our business in an ethical
and legal manner with the highest level of integrity.
To ensure compliance with the laws, industry guidelines, and Galderma standards
applicable to the development, manufacturing, marketing, and sale of our products,
the Company established a Comprehensive Compliance Program (CCP) that is consistent
with the Department of Health and Human Services Office of Inspector General Guidance.
Our CCP takes into consideration the nature of our business, whether it be prescription
drugs, medical devices or consumer products, and is one of the key components of
our commitment to the highest standards of conduct.
The Galderma CCP, comprised of Galderma's Global Code of Ethics, the U.S. Code of
Conduct and Compliance Manuals, summarizes the ethical and legal standards to which
all Galderma employees must adhere. Our CCP is dynamic; we regularly review and
enhance our CCP to meet our evolving compliance needs. The purpose of our CCP is
to prevent and detect violations of law or Company policy. As HHS-OIG calls for
in its Guidance, we have tailored our CCP to fit the unique environment of our Company.
The Company has designated a Chief Compliance Officer with responsibility for developing,
operating, monitoring, and enforcing this program. The Chief Compliance Officer
makes periodic reports to Compliance Committee and reports significant issues directly
to the President of the Company, the General Counsel, and the U.S. Leadership Team.
The Company provides a toll-free telephone line to report suspected violations of
Company policies or laws. Calls can be made anonymously and without fear of retribution
24 hours a day, seven days a week. Allegations of non-compliance are documented
and investigated so that appropriate corrective action can be taken when warranted.
California Transparency in Supply Chains Act of 2010
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