Novartis updated its anti-bribery policy four months after the Swiss pharma paid $346.7 million to resolve FCPA offenses in Greece, Vietnam, and South Korea. Here are some interesting details from the latest version.
1. No gifts, even culturally-appropriate unbranded ones.
Gifts of any kind including personal gifts, cultural acknowledgements or promotional aids etc., whether branded or unbranded, must not be provided to Healthcare Professionals (HCPs) or their family members.
2. Use the “front page” test to avoid embarrassment.
Before giving a gift or providing hospitality or entertainment to anyone, consider whether the reputation of Novartis, yourself, or the recipient is likely to be damaged if news of the gift, hospitality, or entertainment appeared on the front page of a newspaper. If this would embarrass either Novartis or the recipient, do not proceed.
3. No facilitating payments, even if legal.
Novartis prohibits facilitation payments, irrespective of whether local law permits facilitation payments.
4. Public vs. Private? Not so different.
Novartis does not distinguish between public officials and employees of private sector organizations so far as bribery is concerned; however, it is important to recognize that public officials are often subject to rules and restrictions that do not apply to persons who operate in the private sector.
5. In some places, every healthcare professional is a public official.
In some countries, doctors, pharmacists, clinical trials investigators, and nurses are public officials irrespective of whether they are working at a government institution.
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View more anti-corruption policy benchmarks here.