Preventing Corruption & Bribery - Perspectives from the Regulators- Paul Vincke Managing Director EHFCN ETHICS – General Assembly Paris 3 October 2014

Corruption in healthcare Don’t ask……. Don’t tell……

Core Areas of Health Sector Corruption Risks Source: Transparency International, 2006,Global Corruption Report , p7

« Abuse of power for private gain ». (*) Corruption defined « Abuse of power for private gain ». (*) (*)European Commission « 

Institutional corruption(*) “Systemic and strategic influence which is legal, or even currently ethical, that undermines the institution’s effectiveness by diverting it from its purpose, including, to the extent relevant to its purpose, weakening eather the public’s trust in that institution or the institution’s inherent trustworthiness.” (*) Institutional Corruption & Pharmaceutical Policy, Mark Rodwin e.a. Harvard U, August 2013

Medicine supply chain and corruption risks

Blockbuster Strategy… Influencing drug prescription behavior of individual providers and hospitals “Sponsoring” of scientific experts, opinion leaders, scientific societies, conferences and trainings Manipulation of scientific and clinical data Disease mongering Creating a need for life style drugs …. making healthcare more expensive , less effective and affecting the reputation of the industry itself

From Enforcement Practices…

…To Self-Regulation

Procurement Corruption

Improper marketing relations

Misuse of (high level) positions

Conclusions

Recommendations for succesfully targeting corruption in healthcare Introduce and inforce clear-cut anti-corruption legislation Endorse self-regulation and install integrity management Enforce transparency regulations Install accreditation, certification or rating systems Mobilise countervailing powers Reduce the risk of data bias Separate research from marketing Review evidence for off-label use of drugs Develop policies to set new rules within the the medical profession

Corruption Risk Assessment Heatmap Source

Developing and implementing an Anti-Corruption Ethics and Compliance Programme An overview of best practices from: Source

12 main elements in effective business anti-bribery instruments 1. Support commitment from senior management for the prevention of corruption 2. Developing an anti-corruption programme 3. Oversight of the anti-corruption programme 4. Clear, visible and accessible policy prohibiting corruption 5. Detailed policies for particular risk areas 6. Application of the anti-corruption programme to business partner Source

12 main elements in effective business anti-bribery instruments (cont 7. Internal controls and record keeping 8. Communication and training 9. Promoting and incentivising ethics and compliance 10. Seeking guidance – Detecting and reporting violations 11. Adressing violations 12. Periodic reviews and evaluations of the anti- corruption programme Source

The Ultimate Patient Benefit Test Innovation Marketing Is the patient receiving the right drug at the right time at the right cost with the appropriate information ?

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