We all want to do the right thing: Act with honesty and integrity in business and personal dealings. Recently, a growing number of laws, industry and corporate guidelines have been introduced, governing how health care companies should interact with Health Care Professionals. This, within Johnson & Johnson, is referred to as Health Care Compliance.
The intent of Health Care Compliance is to ensure that the focus of our interactions with Health Care Professionals remains on the genuine benefits our products bring to patients. The scope of Health Care Compliance encompasses a wide range of business practices and interactions including: consulting services, hospitality, charitable contributions and educational and research grants. Acting within the Health Care Compliance guidelines and policies will protect the Health Care Professional, our company, our employees and ultimately the patient.
Johnson & Johnson’s corporate guidelines on Health Care Compliance align with the Johnson & Johnson Credo, our statement on ethical practices. Johnson & Johnson have consistently applied the values and standards reflected in our Credo. These Health Care Compliance guidelines will enable us to reinforce and enhance these values. You can rely on Johnson & Johnson to provide:
Whilst it is fair to say that grants, training seminars and consulting arrangements have helped to improve the overall quality of health care in many areas, these activities can potentially be misused for personal gain or corporate advantage, or can be misconstrued as having some personal gain or corporate advantage. Health Care Compliance provides guidance on how these activities appropriately and effectively conducted for the purpose of improved patient care.
There are three main considerations of Health Care Compliance in our industry:
Most importantly, the patient comes first and therefore we must ensure there is no undue influence on any treatment decisions. For this reason the definition of a Health Care Professional is wide and includes any individual, institution, or entity that has the ability to prescribe, acquire or influence the prescription or acquisition of products or services.
Health Care Professionals include doctors, assistants, nurses, pharmacists, paramedics, opticians, members of product formulary committees, clinical investigators and researchers, employees of private and public hospitals and private health insurers, as well as officials of health authorities and Health Care Professionals in training.
Following this, to prove no undue influence, there must be auditable transparency in our dealings with Health Care Professionals. Therefore, we must be more formal in the way we do business and document both our business interactions and our justification for doing them.
Finally, when we succeed in doing the first two, we are protecting the Health Care Professional, our company, our employees and the patient.
We hope this summary clarifies the intent of our future relationships with Health Care Professionals. If you have any questions, please contact your company representative. We are confident that discussions about Health Care Compliance will support and advance our shared commitment to patient care.
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