MedImmune's operations are subject to numerous federal and state laws and regulations. The laws and regulations governing those who manufacture or supply pharmaceutical products are becoming increasingly complex, and MedImmune is committed to conducting all of its business activities in compliance with all applicable laws, rules and regulations. MedImmune's management and employees are dedicated to high ethical standards and recognize MedImmune's duty to conduct its affairs within the bounds of the law. MedImmune invites you to review the following for more information on MedImmune's ethics and compliance activities.
*To receive a hard copy of the MedImmune's Corporate Compliance Program, please contact our Customer Support Network at 877-633-4411
- MedImmune's Global Standards of Business Conduct and Ethics is a summary of the broad ethical and legal principles under which the company operates.
- MedImmune's Comprehensive Compliance Program incorporates the Global Standards of Business Conduct and Ethics as well as standards and procedures for how MedImmune conducts business.* In addition, the program provides MedImmune's employees with a more specific understanding of certain laws, regulations and standards applicable to their jobs.
- MedImmune's commitment to Responsible Procurement and Supplier Diversity applies these Global Standards of Business Conduct and Ethics to MedImmune's business interactions with suppliers.
- Compliance with California Law (California Health & Safety Code §§ 119400-119402 (2005)).
- The Corporate Compliance Officer, in conjunction with the Board of Directors Compliance Committee, provides oversight and guidance to ensure compliance with all applicable laws, rules and regulations and will be responsible for the uniform implementation of the Corporate Compliance Program.
- MedImmune maintains an anonymous, toll-free compliance hotline for employees to report inappropriate activities, raise concerns or to request guidance on conducting their business affairs in an appropriate manner. Calls are not traced or recorded and retaliation against anyone calling the hotline will not be tolerated.
Compliance with the California Law
The State of California recently passed a law, effective July 1, 2005 (California Health & Safety Code §§ 119400-119402 (2005)) mandating that each pharmaceutical manufacturer that interacts with medical or health professionals in California adopt and publish a Comprehensive Compliance Program that is in accordance with the HHS-Office of Inspector General's publication "Compliance Program Guidance for Pharmaceutical Manufacturers." The Comprehensive Compliance Program must include policies that ensure the manufacturer's practices are in compliance with the PhRMA Code on Interactions with Health Care Professionals and also set a specific annual limit for gifts or incentives provided by MedImmune to health or medical professionals in California.
- As required by the California law, MedImmune makes an annual declaration that, in all material respects, MedImmune is in compliance with its Corporate Compliance Program and the California law.
- MedImmune's annual limit for gifts or incentives provided to health or medical professionals in California is included in the Comprehensive Compliance Program.
The PhRMA Code on Interactions with Health Care Professionals addresses interactions with health care professionals in a variety of circumstances, including meals and entertainment, continuing education, and promotional and consulting services. MedImmune is committed to conducting the sales and marketing of its products in a manner consistent with the PhRMA Code and has adopted policies and procedures that describe how to market our products consistent with the PhRMA Code.
MedImmune's Annual Gift Limit In California
Effective July 1, 2005, MedImmune has established an annual gift limit for items or services from MedImmune to a medical or health professional of up to $1500 in value per medical or health professional, not including items of minimal or nominal value. MedImmune anticipates that items of minimal or nominal value provided to any medical or health professional will not exceed more than $10 per item, or more than $50 in the aggregate in any given annual period. The annual gift limit represents the maximum value of items or services covered by the California law that may be provided per medical or health professional annually. The annual limit is not a spending goal, and MedImmune anticipates that the actual average amount per medical or health professional will be siginificantly less than the maximum amount.
MedImmune will use its best efforts to track the aggregate annual value of items (including meals) or services provided to medical or health professionals as required by California Law. MedImmune does not intend to track or record nominal or minimal items given to medical or health professionals, and intends that such items shall only be given consistent with the principles of the PhRMA Code. Further, MedImmune understands the California Law not to include as gifts any items of value provided to medical or health professionals in connection with relationships related to services provided by such individuals for MedImmune, such as consultant services or research, or educational grants not provided directly to such medical or health professionals, or medical or scientific reprints provided to medical or health professionals. MedImmune will assess the annual gift limit from time to time and reserves the right to revise or adjust the annual limit at any time.