Comprehensive Compliance program

Description

I. Introduction

General
Novartis Vaccines and Diagnostics, Inc. ("Novartis V&D") is committed to establishing and maintaining an effective Integrity and Compliance Program in accordance with "Compliance Program Guidance for Pharmaceutical Manufacturers," published by the Office of Inspector General, U.S. Department of Health and Human Services (the "HHS-OIG Guidance"). Our Integrity and Compliance Program is one of the key components of our commitment to the highest standards of corporate conduct.

Purpose
The purpose of our Integrity and Compliance Program is to prevent and detect violations of law or company policies. As the HHS-OIG Guidance recognizes, however, the implementation of such a program cannot guarantee that improper employee conduct will be entirely eliminated. Nonetheless, it is our expectation that employees will comply with our Code of Conduct, and the policies established in support of such a Code. In the event that we become aware of violations of law or company policy, we will investigate the matter and, where appropriate, take disciplinary action and implement corrective measures to prevent future violations.

Described below are the fundamental elements of the Novartis V&D Integrity and Compliance Program. As HHS-OIG calls for in its Guidance, we have tailored our program to fit the unique environment of our company. Moreover, our Integrity and Compliance Program is dynamic; we regularly review and enhance our program to meet our evolving compliance needs.

 

II. Overview of Compliance Program

Leadership
Maureen Rogers, General Counsel and a member of the Novartis V&D Executive Committee, serves as the Chief Compliance Officer, and maintains overall responsibility for the global Novartis V&D Integrity and Compliance program. Ms. Rogers reports directly to Andrin Oswald, CEO of Novartis V&D.

Ms. Rogers has regular and direct access to present integrity and compliance issues to the Novartis V&D Executive Committee and CEO, and as such, has the ability to effectuate change within the organization as necessary and to exercise independent judgment.

Ms. Rogers can be reached at: nvd.integritycompliance@novartis.com

Code of Conduct
Advamed Code of Ethics.

 

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