Anti-Corruption Policy Quiz

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Questions and Answers

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?

  • 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?

  • 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?

<p>Written approval from Compliance is required. (C)</p> Signup and view all the answers

How should the value and frequency of gifts, meals, or hospitality be managed?

<p>They must be modest in value and infrequently provided. (A)</p> Signup and view all the answers

What type of interactions does this policy primarily apply to?

<p>Interactions with Government Officials and healthcare organizations (A)</p> Signup and view all the answers

What should an employee do if they suspect a violation of the policy?

<p>Report it to their manager or compliance team (B)</p> Signup and view all the answers

What is prohibited in relation to reporting a suspected violation?

<p>Retaliation against the reporting individual (B)</p> Signup and view all the answers

What types of activities are considered interactions under this policy?

<p>Scientific discussions and promotional interactions (D)</p> Signup and view all the answers

Who does this policy apply to within Agios?

<p>All employees worldwide (D)</p> Signup and view all the answers

Which channels can employees use to report violations?

<p>Any member of the Compliance team or through the Agios Compliance Helpline (D)</p> Signup and view all the answers

In what circumstances can an employee provide business courtesies like meals and gifts?

<p>When it does not result in a conflict of interest (D)</p> Signup and view all the answers

What is the primary responsibility of Agios employees regarding compliance?

<p>They must comply with this policy and applicable Compliance Handbooks. (C)</p> Signup and view all the answers

Which of the following best describes the training requirement for Agios employees?

<p>Training should occur periodically and in a determined format. (A)</p> Signup and view all the answers

In case of a conflict between policy and applicable laws, what must Agios employees do?

<p>Comply with the strictest standard. (C)</p> Signup and view all the answers

Which of the following actions is explicitly prohibited by Agios' Anti-Corruption Policy?

<p>Engaging in bribery and other corrupt conduct. (C)</p> Signup and view all the answers

Who are considered key risk areas for bribery according to the policy?

<p>Government officials, HCPs, and employees of state-owned institutions. (A)</p> Signup and view all the answers

What should be done if an Agios employee witnesses a compliance violation?

<p>Report it as per company guidelines. (D)</p> Signup and view all the answers

What is a significant requirement of the Compliance Handbook?

<p>It must comply with applicable local laws and regulations. (B)</p> Signup and view all the answers

What is the nature of the document based on its classification at Agios?

<p>Confidential and proprietary to Agios. (C)</p> Signup and view all the answers

Which law relates specifically to interactions with foreign officials regarding bribery?

<p>The Foreign Corrupt Practices Act (FCPA). (A)</p> Signup and view all the answers

What is prohibited in regard to payments made by Agios?

<p>Per diem payments (A)</p> Signup and view all the answers

What must accompany reimbursements made by Agios?

<p>A written receipt (B)</p> Signup and view all the answers

How should Agios handle charitable donations?

<p>Support general fundraising efforts (B)</p> Signup and view all the answers

What is a requirement concerning grants and sponsorships from Agios?

<p>They must support the recipient organization’s legitimate mission (B)</p> Signup and view all the answers

What types of payments are specifically mentioned as acceptable for Agios?

<p>Direct payments to vendors (B)</p> Signup and view all the answers

Under what circumstance will Agios provide a reimbursement?

<p>If direct payment is not reasonably possible (C)</p> Signup and view all the answers

What is a major restriction on donations made by Agios?

<p>Donations cannot benefit a physician group practice (C)</p> Signup and view all the answers

What should Agios avoid when making grants or sponsorships?

<p>Making decisions based on personal connection (D)</p> Signup and view all the answers

How should Agios handle requests for donations?

<p>Fundraise in alignment with their corporate values (C)</p> Signup and view all the answers

Which of the following is a guideline for third-party representatives under Agios's policy?

<p>Avoid using sponsorships for personal gain (D)</p> Signup and view all the answers

What is strictly prohibited when interacting with healthcare professionals (HCPs)?

<p>Paying any benefits to HCPs (B)</p> Signup and view all the answers

What must be done before providing anything of value to an HCP?

<p>Consult and comply with the Global Policy (D)</p> Signup and view all the answers

Which of the following actions is considered a bribe under the policy?

<p>Sponsoring an HCP to attend congresses (D)</p> Signup and view all the answers

Which of the following is an example of an improper financial advantage?

<p>Offering a kickback for referrals (C)</p> Signup and view all the answers

If a person refuses to give a bribe and it results in losing business, what does the policy state?

<p>They will not suffer adverse consequences (D)</p> Signup and view all the answers

What might happen if someone requests a kickback?

<p>They are violating the policy (D)</p> Signup and view all the answers

Which scenario represents a breach of the duty of loyalty?

<p>An HCP being paid to consult (B)</p> Signup and view all the answers

Which activity must not involve any intent to secure an improper advantage?

<p>Offering business meals (D)</p> Signup and view all the answers

What is the consequence of providing something of value to an HCP not covered by a Compliance Handbook?

<p>Consulting local regulations becomes mandatory (C)</p> Signup and view all the answers

What type of agreement is specifically mentioned as needing careful consideration?

<p>Sponsorship agreements (D)</p> Signup and view all the answers

Flashcards

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

Applies to all Agios employees globally, encompassing interactions involving gifts, meals, educational materials, sponsorships, and grants.

Reporting Violations

Employees must report any suspected violation of the anti-bribery policy to their manager, HR, or Compliance/Legal.

Anonymous Reporting

Employees can report alleged violations anonymously through the Agios Compliance Helpline.

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Retaliation Prohibition

Agios prohibits any form of retaliation against employees reporting suspected violations of the policy in good faith.

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Interactions with Stakeholders

This policy covers employee interactions with government officials, healthcare professionals, healthcare organizations, and others in the marketplace, including scientific and promotional discussions.

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Compliance Handbooks

Agios Compliance Handbooks are relevant documents clarifying details related to the broader ethical and compliance initiatives within the company.

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Anti-corruption Policy

Agios prohibits bribery and corrupt practices involving healthcare professionals, government officials, and others in business dealings.

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Applicable Laws

Local laws and regulations, as well as industry guidelines.

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Government Officials

Employees of government agencies, including health ministries, customs, and other institutions.

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Bribery

Offering, giving, receiving, or soliciting anything of value to influence an official action.

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HCPs (Healthcare Professionals)

Medical professionals, doctors, and nurses.

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Conflict between policies

When a company policy is in disagreement with another policy or a law, follow the strongest/most demanding.

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Periodic Training

Regular training programs for employees on anti-corruption policies and laws.

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Strictest Standard

Comply with the most rigid or demanding requirement in cases of conflicting policies.

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Bribery and Corruption

Agios prohibits offering, giving, or receiving anything of value to influence a person or organization for improper gain.

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Agios Policy Scope

This policy applies to all Agios employees, directors, agents, and representatives globally.

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Interactions with HCPs

Agios regulates interactions with healthcare professionals (HCPs) to ensure they're ethically appropriate.

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What's Considered a Bribe?

Activities that could be seen as bribes include providing benefits to HCPs to influence their actions, like fee-for-service agreements or sponsorships.

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Avoiding Improper Advantages

Agios policy aims to prevent employees from gaining an improper advantage through unethical means.

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Protection for Reporting Violations

Employees are protected from retaliation when reporting suspected violations of the policy.

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Interactions in All Countries

Agios's policy applies to interactions in all countries, even those without specific handbooks.

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Consult Before Interacting

Employees must consult with relevant departments before engaging with HCPs to avoid ethical breaches.

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No Retaliation for Refusal

Agios employees are protected from negative consequences for refusing to offer or accept bribes.

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Third-party Representatives

Individuals or organizations acting on behalf of Agios, such as contractors, consultants, or distributors.

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Gifts and Hospitality

Agios can provide modest gifts, meals, or hospitality to clients, but they must be infrequent, appropriate, and not used for unethical purposes.

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Compliance Approval

Agios employees need prior written approval from the Compliance department before providing any gifts, meals, or hospitality to Government Officials.

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Ethics and Due Diligence

Agios must conduct due diligence on third-party representatives to ensure they operate ethically and comply with anti-bribery regulations.

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What does Agios prohibit regarding travel?

Agios prohibits employees from arranging travel for healthcare professionals (HCPs) or government officials if the travel is primarily intended to promote Agios's products or services, or if the travel benefits the HCP or official more than Agios.

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What are the rules for making payments?

Payments to airlines, hotels, or other vendors for HCP travel should be made directly by Agios whenever possible. Reimbursements are allowed with a written receipt if direct payment is not possible. Per diem payments are prohibited.

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What types of support can Agios provide?

Agios can provide grants and sponsorships to legitimate medical and educational organizations to support educational programs, research, or other legitimate missions.

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What are the restrictions on donations?

Donations should be made to legitimate charitable organizations, not individuals or organizations involved in recent Agios marketing or promotion. They should be made in response to general fundraising efforts, not directed requests.

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Who is covered by the anti-corruption policy?

The policy applies to all Agios employees globally. It covers interactions with government officials, HCPs, healthcare organizations, and others in the marketplace.

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What does the policy state about third-party representatives?

Anti-corruption laws cover both direct and indirect payments and benefits. This means that using third-party representatives to make payments or provide benefits could still be considered a violation.

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What is the purpose of the Global Policy on Funding and In-Kind Support of External Organizations?

This policy outlines the guidelines for providing funding and support to external organizations. It ensures that support is legitimate and aligns with Agios's mission.

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What is the role of Agios Compliance Handbooks?

These handbooks clarify details related to the broader ethical and compliance initiatives within the company, providing further guidance on the anti-bribery policy.

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What should employees do if they suspect a violation of the anti-bribery policy?

Employees must report any suspected violation to their manager, HR, or Compliance/Legal. They can also report violations anonymously through the Agios Compliance Helpline.

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What happens if an employee reports a violation in good faith?

Agios prohibits any form of retaliation against employees who report suspected violations 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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