ERM Program
In connection to our ERM program, Internal Audit assesses anti-corruption and anti-fraud management over entities throughout the world from a corruption risk perspective. Size (the number of people and sales volume) and a country’s ranking in the Transparency International Corruption Perception Index (CPI) are key to informing the risk profile of an entity. Entities identified as higher risk along with those of strategic importance to Mylan are a particular focus. Further, we monitor business activities that are deemed an elevated risk – such as HCP interactions – through established internal processes and controls. Our procedures also cover our business partners.
Mylan’s Corporate Compliance Program
Everyone at Mylan – and those acting on our behalf – is personally responsible and accountable for the company’s reputation and dedication to doing business with integrity. Mylan works to provide the adequate procedures and guidance to support that individual responsibility. Mylan’s Chief Administrative and Compliance Officer has the operational responsibility to ensure Mylan’s Corporate Compliance Program is effective and robust and directs its dayto- day implementation. To ensure broad perspectives and independence in the Compliance Office, Mylan’s Chief Administrative and Compliance Officer reports to the board’s Compliance Committee and the Chief Executive Officer.
Mylan’s Compliance department is organized by operating regions and Global Centers of Excellence (CoE) to efficiently support the organization. The Compliance department and Mylan’s Global Compliance Program are structured in a manner consistent with the Office of Inspector General of the U.S. Department of Health and Human Services (OIG) Resource Guide for Measuring Compliance Program Effectiveness. The Chief Administrative and Compliance Officer leads three global CoE that support Mylan’s global operating regions and business. A senior leader manages each respective CoE, which focuses on policies, training and communications, global compliance risk, audit and due diligence, and investigations. The Compliance department oversees the development, maintenance and recordkeeping of global policies and procedures and performs various periodic and needs-based operational audits throughout the year, often in conjunction with Internal Audit.
We also have a Compliance Line in place which is operated by an external party, is available 24/7 and permits anonymous reports in all countries where permitted by law. Compliance-related matters are reviewed by our Head of Global Compliance and investigated in a timely, impartial fashion with all appropriate parties.