Indivior PLC Integrity & Compliance Program
Indivior PLC, (the “Group”) has established a program, in accordance with the Pharmaceutical Research and Manufacturers of America Code on Interactions with Healthcare Professionals (PhRMA Code) and the Compliance Program Guidance for Pharmaceutical Manufacturers published by the U.S. Department of Health and Human Services Office of Inspector General in April 2003 (OIG Guidance), designed to materially comply with applicable federal and state laws and industry standards relating to the marketing and promotion of its products.
Overview of Compliance Program
Written Policies and Procedures
The Group has written policies to assure substantial compliance with the applicable laws and regulations and standards governing the marketing and promotion of our products. The Group has established written policies that govern activities involving interactions with our customers regarding the appropriate use of our products including appropriate instruction, education, training, and technical support required for the safe and effective use of our products. The Group also has policies governing activities involving the advancement of scientific and educational activities supporting medical research and education.
Assigned Compliance Officer
The Group has appointed a Chief Integrity & Compliance Officer who has been empowered with authority to exercise independent judgment and has free and unencumbered access to the Board.
In addition, the Indivior Compliance Committee (ICC) has been formed. The ICC consists of the CEO of the Group and all of his/her direct reports who are also members of the Indivior Executive Committee. The CEO has appointed the Chief Integrity & Compliance Officer (“CICO”) to serve as the chairperson of the ICC.
The Group has an annual Integrity & Compliance Code Of Conduct Training process that is mandated for all employees. New employees receive training at the time of hire and annually thereafter. The training covers applicable guidelines governing our compliance program.
The Group encourages open and candid discussion between management and employees regarding any compliance concerns. Employees are encouraged to report their concerns to their manager or to their Human Resources, Legal or Integrity & Compliance partners. Employees also have the option to report potential policy or integrity violations by calling EthicsLine at 1-855-881-7196 or online at secure.Ethicspoint.com.
Auditing and Monitoring
The Group self-assesses and audits its compliance programs and reviews policies and procedures periodically. Audit observations are tracked to ensure timely closure of any identified items.
Enforcement and Disciplinary Guidelines
The Group will take disciplinary actions in response to violation of the Group’s policies or procedures. An investigation of any matter that is brought to the Group’s attention will be conducted and will be brought to closure in a timely manner.
Responses to Detected Problems and Actions to Correct Issues
The Group responds promptly to any potential violations of the Group’s Integrity & Compliance program. Responses may include additional training, enhanced communications, refinement of policies, or possible disciplinary actions.
Last update: April 29, 2019