C. R. Bard, Inc., on behalf of itself and its subsidiaries (individually and collectively “Bard”), has established and is operating under a Comprehensive Compliance Program (“CCP”) that, where applicable, is in accordance with the “Compliance Program Guidance for Pharmaceutical Manufacturers” developed by the United States Department of Health and Human Services Office of Inspector General. Bard has adopted the Advanced Medical Technology Association Code of Ethics on Interactions with Health Care Professionals (the “AdvaMed Code”). Bard hereby declares that as of July 1, 2010, we believe that in all material respects, Bard is in compliance with its CCP and the requirements of the applicable California Code.1
Corporate Compliance Program Description
C. R. Bard, Inc. (“Bard”) has developed and distributes written compliance standards, procedures, and practices that guide the conduct of its employees and day-to-day operations of Bard and its subsidiaries (individually and collectively the “Company”).
The Company has designated a Chief Compliance Officer who reports to the Company’s CEO and to its Board of Directors regularly on compliance issues, and the Company has established a management compliance committee to assist in continued implementation of its compliance program.
The Company has developed and implemented regular, effective education and training programs for all relevant employees.
The Company has created and maintains an effective line of communication with its employees, including the availability of a compliance telephone hotline (877-285-4158), for its employees to report complaints or ask questions. The compliance hotline is available 24 hours a day, 7 days a week. Calls to the compliance hotline cannot be traced and the system affords callers the opportunity to remain anonymous.
The Company utilizes audits and other risk evaluation techniques to monitor compliance, identify problem areas and assist in the reduction of any identified problems.
The Company has a corporate policy and procedures in place to address the non-employment or retention of individuals or entities excluded from participation in federal health care programs, and a mechanism for the enforcement of appropriate disciplinary action against employees or contractors who have violated the company policies and procedures.
The Company has implemented policies and procedures for the investigation of identified instances of non-compliance or misconduct, including directions regarding the prompt and proper response to detected offenses.
If you would like to receive a copy of the above, please call 877-285-4158.
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