Bausch Health conducts regular risk assessments, inclusive of healthcare compliance risks and various other matters.
We also conduct self-assessments to ensure personnel are operating in compliance with Company policies and procedures. We have regular internal and external audits, as well as targeted compliance monitoring exercises. Examples of activities that are subject to both audits and self-assesses and periodically audits
Periodic monitoring include:
- Promotional interactions with healthcare professionals
- Consulting arrangements
- Meals gifts and other transfers of value to healthcare professionals
- Promotional Speaker Programs
- Transactions that implicate data privacy laws
- Scientific publications
We also maintain a third-party compliance program through which we evaluate our third-party intermediaries for anticorruption and other risks. The program includes, among others, our distributors, organizations that interact with government agencies or officials on our behalf, and those who make payments or transfers of value to healthcare providers. We conduct risk-based diligence at the time we initiate a relationship with a new third-party, as well as periodically thereafter.