Business Conduct

Indivior is committed to high standards of business conduct in line with industry good practice and stakeholder expectations. Indivior has a comprehensive compliance approach to help ensure that everyone within the organization acts in a responsible manner. The Indivior Integrity & Compliance Program (ICP) and other key business management systems are vital components of this approach.

In July 2020, Indivior reached an agreement with the US Attorney’s Office for the Western District of Virginia. As part of the settlement, Indivior entered into a Corporate Integrity Agreement (CIA) with the Office of Inspector General of the U.S. Department of Health and Human Services. Indivior agreed to maintain compliance-related measures, including those that have been put in place to address relations with healthcare professionals, product information, and marketing activities. The agreement included commitments to conduct monitoring, auditing, training, education, reporting, and disclosures for a period of five years.

About the Indivior Integrity & Compliance Program (ICP)

The ICP is modeled on the Elements of an Effective Compliance Program as described in the Federal Sentencing Guidelines for Organizations. It is also based on guidance from the US Department of Justice (DOJ) and the US Health and Human Services’ Office of Inspector General, and relevant national and global industry standards.

The ICP has a multi-year strategy to drive continuous learning and evolution. Overall in 2020, its multiple facets and activities helped to maintain and strengthen Indivior’s commitment to compliance as a core performance indicator.

Program highlights for 2020 include:

The project updated and simplified key policies and procedures, including the Indivior Global Code of Conduct, while incorporating relevant reference to Indivior Inc.’s commitments from the US Government Resolution (i.e. CIA, DOJ Compliance Measures, and FTC Order). It also enhanced Indivior’s standardized compliance risk assessment tools, including third-party due diligence and Risk Assessment and Mitigation Plan (RAMP) processes, with embedded ownership of risks and related mitigation activities. A separate project to design and distribute an Indivior Supplier Code of Conduct commenced in October and will be published and distributed in the first half of 2021.

This project refined the role of the global Indivior Integrity & Compliance Committee and regional Compliance Committees to ensure effective oversight of the administration of the ICP. The activities included embedding a robust network of Compliance Champions across Indivior’s operations. It ensured the allocation of appropriate budget and headcount resources for the ICP to achieve continued program maturity, government agreement preparedness, full staffing of fully qualified compliance professionals, and the performance of required staff development activities.

This project delivered an interactive compliance training program with a comprehensive curriculum for all employees and contingent workers globally. The program included communicating the outcomes of workforce non-compliance as permitted within local laws. It was conducted in partnership with Indivior’s business units and provided real-time, targeted education and training based on findings from compliance audits, monitoring and investigations.

This project aimed to deliver an enhanced ‘Speak Up’ program through the employment of a full-time investigator and the standardization of processes and communications for all reported concerns. Additionally, the Group invested in additional capabilities within the Indivior EthicsLine reporting tool. Compliance monitoring data, including information about the Speak Up program, was distributed to all employees to facilitate shared learning and drive adherence to Indivior’s business conduct standards. An independent Ethics & Compliance Program Perceptions Survey was conducted by Ethisphere. Subsequently an action plan was put in place for continued evolution, although Indivior’s results exceeded all eight Ethisphere benchmark pillars.

ICP activities during 2020 included the performance of independent reviews to simulate and prepare for CIA monitoring activities. Additionally, a further enhanced strategic compliance auditing and monitoring program, based on key risks and core monitoring activities (e.g. CIA standards) and other factors, was implemented after approval from the Integrity & Compliance Committee. A cross-functional Oversight Committee was introduced to review and enforce standards of conduct. This committee also has responsibility for assessing and determining reportable events in relation to CIA and DOJ Compliance Measures. A procedure was also developed to assess potential root-cause analysis of compliance deviations to enable identification of effective systemic resolution as warranted.