The Global Business Ethics and Compliance Program is dedicated to ensuring that our business is conducted with integrity and is compliant with applicable laws. This program is led by the Global Business Ethics and Compliance Officer, with guidance from the Global Business Ethics and Compliance Committee. They are supported by regional compliance officers and committees. The program consists of the following key elements:
The Apobiologix Code of Conduct and Business Ethics provides guidance to employees regarding the ethical, legal and compliance principles of the company. The Code of Conduct and Business Ethics is supplemented by various compliance policies, procedures and processes for individual business functions.
Training sessions and educational materials about expectations for compliant and ethical behaviour of employees.
Communication channels and tools for employees, customers and vendors to report concerns or misconduct, anonymously and without reprisals for employees (e.g., the Global Business Ethics and Compliance Helpline, www.ApoSpeaks.com).
Systems and procedures to assess adherence to the Code of Conduct and other compliance related matters, and to identify opportunities for enhancing ethical behaviours.
Taking appropriate action to validate and address issues, when concerns or allegations about misconduct or non-compliance arise.
In accordance with the California Law, which states that the Comprehensive Compliance Program shall specify an annual dollar limit on gifts, promotional items or activities that a pharmaceutical company may provide to an individual medical or healthcare professional who resides or practices in the State of California, Apobiologix has established an aggregate, annual dollar limit of $2,500. The dollar limit is a maximum only. As per the state law, bona fide services and similar payments permitted under the PhRMA Code are excluded from the calculation.
Based upon our good faith understanding of the California Health and Safety Code sections 119400 and 119402, Apobiologix declares that we are in compliance with our comprehensive Compliance Program for our commercial operations as well as with California Health & Safety Code section 119402 (California Law).
April 1, 2016
2400 North Commerce Parkway,
Weston, Florida 33326