Business Conduct

The Group requires compliance with laws, regulations, and industry codes of conduct at all times via established policies and procedures. Its comprehensive compliance program includes a focused Integrity and Compliance department, with our Chief Integrity and Compliance Officer as a member of the Executive Committee.


The Integrity and Compliance department helps assure that the Group’s operations are conducted in line with all legal and regulatory requirements, guidance from the Office of Inspector General for the U.S. Department of Health and Human Services, and the appropriate industry codes of ethics, including those published by the Pharmaceutical Research and Manufacturers of America (PhRMA); Association of the British Pharmaceutical Industry; and by Medicines Australia.


In 2018, the Group continued to enhance its Integrity and Compliance program through the implementation of the following (among other key deliverables):


‹ undertaking a comprehensive review of key internal processes, including implementation of appropriate enhancements;

‹ conducting ‘distributor country’ compliance training and supported multiple distributor audits;

‹ developing and disseminating an enterprise-wide quarterly Integrity and Compliance newsletter to drive awareness and best practice throughout the organization;

‹ adopting gamification as an approach to reinforce the field-based sales team’s knowledge of and compliance with policies; and

‹ appointing the Executive Committee to serve as the Indivior Compliance Committee.