California Health & Safety Code §§ 119400-119402
Our Company Compliance Program has been developed by the Implant Direct Compliance Department, and is managed by the President/Chief Compliance Officer (CCO). Our President leads the Company’s Compliance Committee, which meets on a quarterly basis.
Our Company has enacted written policies and procedures implementing its high ethical standards and meeting its healthcare compliance obligations under applicable laws, regulations and industry codes of conduct. These policies apply to all Company employees and compliance with those policies is a condition of employment.
One such policy is the Danaher Code of Conduct, revised and updated in 2011. Each employee is required annually to certify that he/she has read, understands and agrees to comply with the Code of Conduct, and to disclose knowledge of any suspected or actual ethics or compliance issues, concerns or violations.
Our Company has sales specialists located in California. Through those sales specialists, and otherwise, the company conducts promotional activities with California healthcare providers. The company has established a $2,500 annual limit on promotional spending per California medical and health professionals, which includes persons licensed by California to prescribe prescription products, medical students, and members of drug formulary committees.
We provide ethics and compliance training to all sales, marketing and research and development associates. We train on our Code of Conduct, company policies and applicable compliance laws, regulations and industry codes. We provide training to new employees, include compliance training in our initial sales training curriculum, and provide both annual and ad hoc compliance training as appropriate. We provide compliance guidance at company meetings and respond to compliance questions from employees.
Our Company is committed to maintaining a work environment where all individuals encourage and embrace open discussion across both geographical and operational boundaries. Employees are encouraged to seek guidance in resolving ethics and compliance questions. They can do so directly with the Compliance Department. They are required to report suspected or actual unethical or non-compliant conduct, violations of law or regulation and violations of the Code of Conduct or Company policies. Access is provided to an independent, third-party operated, Compliance Hotline where employees and third parties can make such reports anonymously and without retaliation.
Our Company performs compliance gap analyses, process reviews and data analysis to identify and address potential issues and opportunities to enhance its processes and practices. These are collaborative efforts between the Compliance Department and the business which have generated the development of new and revised policies, new training and communications initiatives and corrective action
Our Compliance Department monitors company functions and activities for potential violations of law, regulation, industry codes, the Code of Conduct and company policies. Potential violations are promptly and thoroughly investigated and appropriate corrective action taken.
In determining the appropriate response to an established violation, our Company considers various options for corrective action. These options include closing any gaps in policies, practices or training that may have led or contributed to the violation and the imposition of disciplinary action, up to and including termination.