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government employees. These laws
apply even when the payment is made
outside of the home country.
In the United States there is a related
anti-bribery law, known as the antikickback
law, that prohibits inducing
someone to recommend or purchase
a healthcare product or service covered
by a federal healthcare program. The
purpose of this healthcare law is to
eliminate the influences of money or
things of value in the selection of such
products or services.
This means:- Never, either directly or through an
agent or other third party, making
payments or offering gifts, services
or anything of value to government
employees, employees of public
institutions, or persons that prescribe,
purchase or promote the Company's
products that are intended to
influence or even appear to be
intended to influence that person's
actions with respect to the Company.
- Always exercising great care and
vigilance when entering into
transactions with employees of public
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(Continued)
...that this money is not used as a
bribe. You must seek the advice of your manager, the Global Law department or your local
Compliance Officer before entering into this arrangement.
Q. A regulatory official from
Thailand is visiting our New
Jersey facilities in connection
with a new drug application.
He wants to bring his wife and
make a stop in Los Angeles.
Can we pay for this?
A. It would be appropriate to
reimburse reasonable expenses for the trip from Thailand to
New Jersey for an official with legitimate reason for inspecting
our facilities as long as it is permitted under local law.
However, we cannot pay the expenses for his wife and the
stopover in Los Angeles.
Q. We missed a deadline for
filing an official document and it has been suggested that we
backdate the document to bring it within the deadline. Can we
do this?
A. The U.S. Foreign Corrupt Practices Act has a requirement
for accurate recording of all transactions in the Company's books and records, which is
separate from the prohibition of improper payments to government officials.
(Continued on next page)
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