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

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

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

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

5. 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

6. Medicine supply chain and corruption risks

7. 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

8. From Enforcement Practices…

9. …To Self-Regulation

11. Procurement Corruption

12. Improper marketing relations

13. Misuse of (high level) positions

14. Conclusions

15. 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

17. Corruption Risk Assessment
Heatmap
Source

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

19. 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

20. 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

21. 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 ?

23. Join the fight against fraud and corruption in healthcare
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