Galderma is committed to ensuring
that its business is conducted in an ethical and legal manner.
To ensure compliance with the
laws, industry guidelines and Galderma standards applicable to
the sale and marketing of our products, the Company established
a Compliance Plan that is consistent with the Department of
Health and Human Services Office of Inspector General Guidance.
The Company designated a Compliance Officer with responsibility
for developing, operating and monitoring this program. The
Compliance Officer makes periodic reports to Compliance
Committee and has the authority to report significant issues
directly to the General Counsel, the President of the Company,
and its governing board.
The Galderma Compliance Plan,
along with other policies, summarizes the ethical and legal
standards to which all Galderma employees must adhere in many
areas, including the promotion, marketing and sale of the
Company's pharmaceutical products. In addition, specific
policies and procedures are written and revised as needed. These
policies help ensure compliance with applicable codes and
include restrictions on gifts or incentives to healthcare
professionals.
Galderma supports appropriate
promotion and marketing practices through the training and
certification of our employees. The Company provides a toll-free
telephone line to report suspected violations of Company
policies or legal requirements. 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. The Compliance Plan and the Company's promotion
and marketing practices are audited on a routine basis to ensure
that these activities comply with all federal healthcare program
requirements and meet Galderma's goals for high ethical
standards in the conduct of its business.
Comprehensive Compliance Plan
California
Vermont
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