Bausch Health maintains a rigorous, comprehensive, and effective Ethics & Compliance program that adheres to the legal and regulatory requirements of the markets in which we operate. We routinely assess our program against the “Compliance Program Guidance for Pharmaceutical Manufacturers,” published by the US Department of Health and Human Services’ Office of Inspector General (“OIG”), as well as applicable national and local laws and industry codes. In the United States, our pharmaceutical businesses adhere to the PhRMA “Code of Interactions with Healthcare Professionals.”
We dedicate significant effort and resources toward implementing and sustaining our Ethics & Compliance Program, including checks and balances to prevent and detect violations of law or Company policy.
Key elements of the Ethics & Compliance Program include:
- Compliance Governance A dedicated Corporate Compliance Function, led by our Chief Ethics & Compliance Officer under the direction of the Audit and Risk Committee of the Board of Directors.
- Policies and Procedures Comprehensive sets of rules, practices and procedures, including our Code of Conduct, which guide the organization’s day-to-day practices.
- Training and Awareness Regular communication, through various media, to ensure personnel understand and adhere to the rules applicable to their roles.
- Auditing, Monitoring and Risk Assessments Targeted, risk-based review of certain business activities focused on detecting potential misconduct, as well as regular comprehensive assessments evaluating the organization’s regulatory risk areas and associated controls.
- Misconduct Reporting Mechanisms Various avenues for employees to raise compliance concerns, including an anonymous hotline maintained by an independent third-party.
- Well publicized disciplinary guidelines Clear and specific consequences for individuals who violate the law, our Code of Conduct, or other company policies.
Please click here to review the Annual California Compliance Declaration.