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Compliance Program Overview

Introduction

DEY, L.P. (DEY) is committed to establishing and maintaining an effective Corporate Compliance Program (the "Compliance Program") in accordance with the "Compliance Program Guidance for Pharmaceutical Manufacturers," published by the U.S. Department of Health and Human Services Office of Inspector General (the "HHS-OIG Guidance"). DEY's success is based on its employees' steadfast adherence to the highest ethical and applicable legal standards. DEY® is committed to continuous improvement of its Compliance Program, and the proactive identification of areas that the Compliance Program should address.

Responsibility of Compliance

Each DEY employee is responsible for conforming his or her own conduct to the highest ethical standards. The Office of Compliance is responsible for implementing and updating the Compliance Program and providing training on the Compliance Program.

Corporate Compliance Program Overview

DEY has described below the fundamental elements of our Compliance Program. As HHS-OIG calls for in its guidance, DEY has tailored its Compliance Program to fit the unique environment of our company. Our Compliance Program is dynamic; we regularly review and enhance our Compliance Program to meet our evolving compliance needs and the ever-changing regulatory and legal environment guiding our industry.

As part of the Compliance Program, DEY has developed written policies and procedures governing specific activities of employees in their dealings with providers, patients, government and industry. However, as the HHS-OIG Guidance recognizes, the implementation of such program cannot guarantee that improper employee conduct will be entirely eliminated. Nevertheless, it is DEY's expectations that employees will comply with the policies and procedures of the Compliance Program. DEY's policies address areas such as:

  • Proper disclosure of data to Federal and State health program administrators
  • Restrictions on gifts to, and services for, physicians and other health care providers
  • Anti-kickback law compliance
  • Anti-trust law compliance
  • Permissible distribution of prescription drug and device samples
  • Annual compliance education and training

A guiding principal of the Compliance Program is open access to the Office of Compliance. Any DEY employee with a concern about corporate compliance or question on the application of these policies may bring that concern, in confidence, to the Chief Compliance Officer by calling the compliance hotline at 1-866-DEY-ETHIC (1-866-339-3844).