Certify Pharmaceutical Sales Compliance with the PhRMA Code Guidelines

I GLASS Method™ - Compliance Enforcement Trends

Companies require more than written compliance programs to avoid harsher penalties.

		Companies need to ensure that compliance policy is translated into compliant behavior in the field

		Companies need to monitor behavior in the field and demonstrate ability to respond to issues and violations

Compliance programs deemed “ineffective” by government prosecutors:

		Become a “red flag” for DOJ and SEC investigations

		Will be fined at higher levels for compliance violations

Individuals are being prosecuted for civil and criminal violations:

		Board Members and other Senior Leaders

		District and Regional Managers

		Sales Professionals

Recent CIAs have required Board Members and Senior Mangers to certify that they have taken all steps necessary to ensure compliance programs are effective

		How does a corporation know that it has an effective compliance program?