Ferring’s Compliance Program
Ferring has a well-structured corporate compliance program designed to support legal and ethical actions throughout the Company. It is principally composed of the Chief Compliance Officer and the Corporate Compliance Risk Committee. Ferring’s Effective Compliance Program is as follows:
Elements of the Compliance Program
1. Leadership and Structure
Chief Compliance Officer
The Chief Compliance Officer is responsible for overseeing Ferring’s corporate compliance program, including the monitoring and self-evaluation programs relating to the legal and regulatory obligations of the Company. The Chief Compliance Officer also has responsibility for documenting, researching, investigating and managing all reported activities of alleged non-compliance. The Chief Compliance Officer ensures that there is consistent interpretation of our standards throughout the Company. In addition to investigating matters and promoting compliance with our standards of conduct, the Chief Compliance Officer engages in a number of proactive efforts to strengthen Ferring’s culture of performance with integrity, including the execution of risk assessments, deployment of targeted training, and the delivery of ongoing communications and compliance education initiatives. The Chief Compliance Officer chairs the Corporate Compliance Risk Committee and the Corporate Compliance Oversight Committee. The Chief Compliance Officer reports to the General Counsel of Ferring Group and the CEO of Ferring Holding, Inc.
Your central resource for compliance information and contacts is the compliance section of the Ferring USA website, http://ferringusa.com. The website contains helpful information and other resources about the laws, policies, and procedures summarized in The Guide. On this website, you also can find the name and contact information for the Chief Compliance Officer.
Compliance with Laws and Regulations
We are committed to complying with all laws, rules and regulations relating to Ferring’s business and all Ferring policies, procedures and guidelines. Many aspects of our business are governed by laws and regulations, including the research, development, manufacturing and marketing of pharmaceutical products, and dealings with government agencies or regulatory authorities. Each employee must understand and follow the legal and regulatory requirements, as well as Company requirements, that apply to his or her responsibilities.
2. Written Policies and Procedures
Ferring ensures employees are trained through internal SOPs, Code of Conduct and training curriculum that focuses on addressing risk areas identified in the HHS-OIG Guidance and the requirements of the PhRMA and AdvaMed Codes on Interactions with Healthcare Professionals. Our Code of Conduct specifically focuses on Ferring’s principles with Integrity, our standards and thoroughly outlines Ferring’s Compliance Program. All Ferring employees are provided with literature for Conducting Business with Integrity outlining the responsibilities of the Corporate Compliance Group and colleagues. Additionally, Ferring has adopted policies and procedures to address the specific risk areas addressed in the OIG Guidance and to incorporate the principles of the revised PhRMA code and the revised Advanced Medical Technology Association Code of Ethics on Interactions with Healthcare Professionals (“AdvaMed Code”).
3. Effective Training and Education
Ferring provides employees with Compliance training to assist them in meeting the responsibility of conducting Ferring business in an ethical manner. Each employee is required to certify that he/she has completed this training program. Employees receive annual training that covers Ferring policies and procedures and the legal rules that apply to those programs including, but not limited to, arrangements with healthcare providers (e.g. consulting agreements, speaker programs). Employees must certify completion of all training.
4. Effective Lines of Communication
Ferring maintains an “AlertLine” to enable employees with a confidential call number to make anonymous complaints regarding accounting or auditing misconduct or violations of the company’s Code of Conduct and to promote a positive work environment. Ferring is committed to a confidential, to the extent allowed by law, and non-retaliation disclosure process.
5. Internal Auditing and Monitoring
Ferring Pharmaceutical’s Compliance program includes activities to monitor, audit, and evaluate compliance with the Company’s policies and procedures.
In accordance to the OIG’s Compliance Program Guidance, Ferring’s approach includes a targeted approach based on identifed and then prioritized risk areas.
6. Disciplinary Guidelines
Ferring Alert Line
The Ferring Alert Line is a toll-free phone number (1-800-446-1494) that you can call or access to report your concerns about unethical behavior if you are not comfortable discussing them face-to-face. The Ferring Alert Line is available 24 hours a day, 7 days a week. It never uses call tracing or recording devices, and if you wish, you may remain completely anonymous.
The Alert Line representatives will listen to concerns, ask questions, and review the information provided. They will then forward matters to Ferring’s Global Ethics Officer, who will take appropriate action. Callers can also arrange to receive information about the Company’s response to the call.
Violations of Ferring’s compliance policies and procedures subject employees to disciplinary action. Employees who fail to comply with these policies and procedures, or who negligently or willfully fail to detect and report violations of these policies and procedures, will be subject to investigation which could include, up to and including termination.
7. Corrective Action
Ferring’s compliance program is enforced to prevent and detect unlawful and unethical behavior. However, as recognized in the OIG Guidance, no compliance program can completely eliminate the possibility that an individual employee or employees may engage in conduct that would be considered improper. As part of Ferring’s compliance program, internal investigation and corrective action processes have been established to undertake corrective action and preventive measures, which are implemented as appropriate.
Important Contact Information
ATTN: Compliance Office
100 Interpace Parkway
Parsippany, NJ 07054