Podcast
Questions and Answers
What is required for gifts, meals, or hospitality provided to Healthcare Professionals?
What is required for gifts, meals, or hospitality provided to Healthcare Professionals?
- They must comply with the Global Policy on Funding and In-Kind Support.
- They must be lavish and frequent.
- They must be approved by Compliance. (correct)
- They must be disclosed publicly regardless of value.
What principle must Agios employees ensure in relation to third-party representatives?
What principle must Agios employees ensure in relation to third-party representatives?
- They must follow the third-party representatives' guidelines only.
- They must conduct business ethically according to company policy. (correct)
- They must provide lavish meals to maintain good relationships.
- They must discourage all interactions with Government Officials.
What is the status of gifts and meals provided as an incentive to secure business at Agios?
What is the status of gifts and meals provided as an incentive to secure business at Agios?
- They are acceptable with prior approval.
- They are prohibited. (correct)
- They are allowed if modest.
- They are encouraged if documented.
What approval is needed for gifts provided to Government Officials?
What approval is needed for gifts provided to Government Officials?
How should the value and frequency of gifts, meals, or hospitality be managed?
How should the value and frequency of gifts, meals, or hospitality be managed?
What type of interactions does this policy primarily apply to?
What type of interactions does this policy primarily apply to?
What should an employee do if they suspect a violation of the policy?
What should an employee do if they suspect a violation of the policy?
What is prohibited in relation to reporting a suspected violation?
What is prohibited in relation to reporting a suspected violation?
What types of activities are considered interactions under this policy?
What types of activities are considered interactions under this policy?
Who does this policy apply to within Agios?
Who does this policy apply to within Agios?
Which channels can employees use to report violations?
Which channels can employees use to report violations?
In what circumstances can an employee provide business courtesies like meals and gifts?
In what circumstances can an employee provide business courtesies like meals and gifts?
What is the primary responsibility of Agios employees regarding compliance?
What is the primary responsibility of Agios employees regarding compliance?
Which of the following best describes the training requirement for Agios employees?
Which of the following best describes the training requirement for Agios employees?
In case of a conflict between policy and applicable laws, what must Agios employees do?
In case of a conflict between policy and applicable laws, what must Agios employees do?
Which of the following actions is explicitly prohibited by Agios' Anti-Corruption Policy?
Which of the following actions is explicitly prohibited by Agios' Anti-Corruption Policy?
Who are considered key risk areas for bribery according to the policy?
Who are considered key risk areas for bribery according to the policy?
What should be done if an Agios employee witnesses a compliance violation?
What should be done if an Agios employee witnesses a compliance violation?
What is a significant requirement of the Compliance Handbook?
What is a significant requirement of the Compliance Handbook?
What is the nature of the document based on its classification at Agios?
What is the nature of the document based on its classification at Agios?
Which law relates specifically to interactions with foreign officials regarding bribery?
Which law relates specifically to interactions with foreign officials regarding bribery?
What is prohibited in regard to payments made by Agios?
What is prohibited in regard to payments made by Agios?
What must accompany reimbursements made by Agios?
What must accompany reimbursements made by Agios?
How should Agios handle charitable donations?
How should Agios handle charitable donations?
What is a requirement concerning grants and sponsorships from Agios?
What is a requirement concerning grants and sponsorships from Agios?
What types of payments are specifically mentioned as acceptable for Agios?
What types of payments are specifically mentioned as acceptable for Agios?
Under what circumstance will Agios provide a reimbursement?
Under what circumstance will Agios provide a reimbursement?
What is a major restriction on donations made by Agios?
What is a major restriction on donations made by Agios?
What should Agios avoid when making grants or sponsorships?
What should Agios avoid when making grants or sponsorships?
How should Agios handle requests for donations?
How should Agios handle requests for donations?
Which of the following is a guideline for third-party representatives under Agios's policy?
Which of the following is a guideline for third-party representatives under Agios's policy?
What is strictly prohibited when interacting with healthcare professionals (HCPs)?
What is strictly prohibited when interacting with healthcare professionals (HCPs)?
What must be done before providing anything of value to an HCP?
What must be done before providing anything of value to an HCP?
Which of the following actions is considered a bribe under the policy?
Which of the following actions is considered a bribe under the policy?
Which of the following is an example of an improper financial advantage?
Which of the following is an example of an improper financial advantage?
If a person refuses to give a bribe and it results in losing business, what does the policy state?
If a person refuses to give a bribe and it results in losing business, what does the policy state?
What might happen if someone requests a kickback?
What might happen if someone requests a kickback?
Which scenario represents a breach of the duty of loyalty?
Which scenario represents a breach of the duty of loyalty?
Which activity must not involve any intent to secure an improper advantage?
Which activity must not involve any intent to secure an improper advantage?
What is the consequence of providing something of value to an HCP not covered by a Compliance Handbook?
What is the consequence of providing something of value to an HCP not covered by a Compliance Handbook?
What type of agreement is specifically mentioned as needing careful consideration?
What type of agreement is specifically mentioned as needing careful consideration?
Flashcards
Agios Anti-Bribery Policy
Agios Anti-Bribery Policy
A global policy requiring Agios employees to comply with anti-bribery and anti-corruption laws when interacting with government officials, healthcare professionals, and others.
Policy Application
Policy Application
Applies to all Agios employees globally, encompassing interactions involving gifts, meals, educational materials, sponsorships, and grants.
Reporting Violations
Reporting Violations
Employees must report any suspected violation of the anti-bribery policy to their manager, HR, or Compliance/Legal.
Anonymous Reporting
Anonymous Reporting
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Retaliation Prohibition
Retaliation Prohibition
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Interactions with Stakeholders
Interactions with Stakeholders
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Compliance Handbooks
Compliance Handbooks
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Anti-corruption Policy
Anti-corruption Policy
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Applicable Laws
Applicable Laws
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Government Officials
Government Officials
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Bribery
Bribery
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HCPs (Healthcare Professionals)
HCPs (Healthcare Professionals)
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Conflict between policies
Conflict between policies
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Periodic Training
Periodic Training
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Strictest Standard
Strictest Standard
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Bribery and Corruption
Bribery and Corruption
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Agios Policy Scope
Agios Policy Scope
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Interactions with HCPs
Interactions with HCPs
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What's Considered a Bribe?
What's Considered a Bribe?
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Avoiding Improper Advantages
Avoiding Improper Advantages
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Protection for Reporting Violations
Protection for Reporting Violations
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Interactions in All Countries
Interactions in All Countries
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Consult Before Interacting
Consult Before Interacting
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No Retaliation for Refusal
No Retaliation for Refusal
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Third-party Representatives
Third-party Representatives
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Gifts and Hospitality
Gifts and Hospitality
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Compliance Approval
Compliance Approval
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Ethics and Due Diligence
Ethics and Due Diligence
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What does Agios prohibit regarding travel?
What does Agios prohibit regarding travel?
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What are the rules for making payments?
What are the rules for making payments?
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What types of support can Agios provide?
What types of support can Agios provide?
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What are the restrictions on donations?
What are the restrictions on donations?
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Who is covered by the anti-corruption policy?
Who is covered by the anti-corruption policy?
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What does the policy state about third-party representatives?
What does the policy state about third-party representatives?
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What is the purpose of the Global Policy on Funding and In-Kind Support of External Organizations?
What is the purpose of the Global Policy on Funding and In-Kind Support of External Organizations?
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What is the role of Agios Compliance Handbooks?
What is the role of Agios Compliance Handbooks?
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What should employees do if they suspect a violation of the anti-bribery policy?
What should employees do if they suspect a violation of the anti-bribery policy?
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What happens if an employee reports a violation in good faith?
What happens if an employee reports a violation in good faith?
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Study Notes
Anti-Corruption Policy
- Agios has zero tolerance for bribery and corruption
- Adheres to ethical conduct globally
- Complies with laws like the FCPA (Foreign Corrupt Practices Act)
- Focuses on interactions with healthcare professionals (HCPs) and government officials
- Policy applies to all worldwide employees & third-party representatives
- Violations can result in criminal/civil penalties, reputational damage, termination, fines and imprisonment
- Reporting violations encouraged via manager, HR, Compliance, Legal or anonymous helpline
- Employees must undergo periodic anti-corruption and bribery training
- Interactions with HCPs and government officials must be transparent
- Gifts, meals, and hospitality provided should be modest and infrequent
- Charitable donations must be used for legitimate purposes, not bribes
Key Risk Areas
- Interactions with government officials (employees, customs, etc.) must be handled carefully, as these officials may be considered as government officials by virtue of employment
- Providing benefits or interactions with HCPs (Healthcare Professionals) must ensure that no improper influence or advantage is sought or given.
Policy Details
- Bribery, kickbacks, improper inducements forbidden (includes anything of value)
- No Agios employee may offer, agree to receive, or accept bribes in any form
- Use of personal funds/benefits prohibited to secure benefits for the company
- Interactions with government officials must follow rigorous guidelines
- Travel expenses to government officials/HCPs must have prior approval. Must have a legitimate business purpose. Can't be excessive; no accompanying friends/family.
- Political contributions prohibited without legal approval
- Facilitating payments (e.g., expedite routine government actions) are forbidden.
- Employment decisions must be objective, based on legitimate business needs, not to gain influence with government officials.
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