1. Seven Ways To Protect Your Company
Robert S. Litt
Arnold & Porter LLC

2. Seven Ways to Protect Your Company
Legal as Input Or
Why is a Lawyer Like an Insurance Policy?

3. Seven Ways to Protect Your Company
One: Have a Real Compliance Program
Show Your Commitment to Law, Don’t Tell It

4. Seven Ways to Protect Your Company
DOJ: “A truly effective compliance program may result in a decision to charge only the corporation’s employees and agents.”

5. Seven Ways to Protect Your Company
OIG: “A good faith effort by the company to comply demonstrated by an effective compliance program, significantly reduces the risk of unlawful conduct and any penalties that result from such behavior.”

6. Seven Ways to Protect Your Company
Training, Supervision and Discipline

7. Seven Ways to Protect Your Company
Two: Separate Science and Sales
Safety Counts!

8. Seven Ways to Protect Your Company
Three: Sometimes the Envelope Breaks if You Push Too Hard

9. Seven Ways to Protect Your Company
Four: Investigate and Remediate

10. Seven Ways to Protect Your Company
Five: To Cooperate or Not To Cooperate?

11. Seven Ways to Protect Your Company
Six: Don’t Say Too Much Too Soon

12. Seven Ways to Protect Your Company
Seven: The Cost of Saving Your Company:
Throwing Culpable Individuals Overboard
Deferred Prosecution/Corporate Integrity Agreement
Monitor

13. Seven Ways to Protect Your Company
Resources:
DOJ McNulty Memorandum:
DOJ Memo on Monitors:
HHS OIG Guidance on Compliance (Pharma):
Recent Medical Device Criminal Settlements:
can be found at
9/27/07 releases