Podcast
Questions and Answers
What is the primary objective of Agios's Anti-Corruption Policy?
What is the primary objective of Agios's Anti-Corruption Policy?
- To engage in competitive bribery practices
- To promote employee bonuses for compliance
- To increase profits through aggressive tactics
- To ensure high standards of ethical conduct (correct)
What is a potential consequence for employees violating the Anti-Corruption Policy?
What is a potential consequence for employees violating the Anti-Corruption Policy?
- Promotion within the company
- Recognition as an employee of the month
- Termination and criminal charges (correct)
- Monetary bonuses
Which law is specifically mentioned in the context of anti-bribery compliance?
Which law is specifically mentioned in the context of anti-bribery compliance?
- U.S. Foreign Corrupt Practices Act (FCPA) (correct)
- International Trade Law
- Local State Privacy Laws
- Global Anti-Corruption Act
Who is required to adhere to the ethical standards outlined in the Anti-Corruption Policy?
Who is required to adhere to the ethical standards outlined in the Anti-Corruption Policy?
What unique risks does Agios face in its sector?
What unique risks does Agios face in its sector?
Which type of interactions requires careful attention under the Anti-Corruption Policy?
Which type of interactions requires careful attention under the Anti-Corruption Policy?
What can happen if Agios does not comply with anti-corruption laws?
What can happen if Agios does not comply with anti-corruption laws?
Who is responsible for ensuring that third-party representatives comply with the Anti-Corruption Policy?
Who is responsible for ensuring that third-party representatives comply with the Anti-Corruption Policy?
What is the main purpose of the policy outlined in the content?
What is the main purpose of the policy outlined in the content?
Who is required to comply with this policy?
Who is required to comply with this policy?
Which of the following interactions is mentioned as applicable under the policy?
Which of the following interactions is mentioned as applicable under the policy?
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 types of activities are considered interactions under this policy?
What types of activities are considered interactions under this policy?
What is the stance of Agios regarding retaliation for reporting suspected violations?
What is the stance of Agios regarding retaliation for reporting suspected violations?
Where can anonymous reports of violations be made?
Where can anonymous reports of violations be made?
The policy is intended to be read in conjunction with which of the following?
The policy is intended to be read in conjunction with which of the following?
What is the primary responsibility of Agios employees regarding the global policy?
What is the primary responsibility of Agios employees regarding the global policy?
How should the training schedule for Agios employees be determined?
How should the training schedule for Agios employees be determined?
In the event of a conflict between the global policy and an applicable law, which standard should Agios employees comply with?
In the event of a conflict between the global policy and an applicable law, which standard should Agios employees comply with?
Which of the following is prohibited under Agios's Anti-Corruption Policy?
Which of the following is prohibited under Agios's Anti-Corruption Policy?
Who are included in the key risk areas for the prohibition against bribery?
Who are included in the key risk areas for the prohibition against bribery?
What does the global policy state about the ownership of the Compliance Handbook?
What does the global policy state about the ownership of the Compliance Handbook?
Which laws are highlighted as significant in the enforcement of anti-corruption policies?
Which laws are highlighted as significant in the enforcement of anti-corruption policies?
What type of conduct is Agios’s Anti-Corruption Policy specifically concerned with?
What type of conduct is Agios’s Anti-Corruption Policy specifically concerned with?
What is classified as a bribe or kickback?
What is classified as a bribe or kickback?
When can travel expenses be provided to a Government Official or HCP?
When can travel expenses be provided to a Government Official or HCP?
What must Agios employees do before providing any travel to a Government Official or HCP?
What must Agios employees do before providing any travel to a Government Official or HCP?
What criteria must be met for travel expenses to be approved?
What criteria must be met for travel expenses to be approved?
What aspect of interactions with Government Officials and HCPs is emphasized?
What aspect of interactions with Government Officials and HCPs is emphasized?
Under what condition can personal funds be used by Agios employees?
Under what condition can personal funds be used by Agios employees?
What is a risk associated with accepting gifts or entertainment from HCPs?
What is a risk associated with accepting gifts or entertainment from HCPs?
Why must benefits to HCPs and Government Officials be approached with caution?
Why must benefits to HCPs and Government Officials be approached with caution?
What is the highest risk associated with third-party representatives?
What is the highest risk associated with third-party representatives?
What must be ensured regarding any gifts, meals, or hospitality provided by Agios?
What must be ensured regarding any gifts, meals, or hospitality provided by Agios?
What is prohibiting regarding Agios' employees and third-party representatives?
What is prohibiting regarding Agios' employees and third-party representatives?
What type of agreement must contractors or third parties have when engaged by Agios?
What type of agreement must contractors or third parties have when engaged by Agios?
What is the stance on lavish meals and gifts provided by Agios?
What is the stance on lavish meals and gifts provided by Agios?
What must be done before providing gifts, meals, or hospitality to Government Officials?
What must be done before providing gifts, meals, or hospitality to Government Officials?
What criteria must Agios’ third-party representatives meet in their business conduct?
What criteria must Agios’ third-party representatives meet in their business conduct?
What is required to support third-party representatives acting on behalf of Agios?
What is required to support third-party representatives acting on behalf of Agios?
Study Notes
Anti-Corruption Policy Purpose
- Agios has a zero-tolerance policy for bribery and corruption in all operations.
- Compliance with this policy is mandatory for all employees, consultants, vendors, suppliers, agents, and third-party representatives.
- Failure to comply can result in legal penalties for Agios and individual employees, including fines, criminal charges, and imprisonment.
Anti-Corruption Policy Scope
- The policy applies to all interactions with government officials, healthcare professionals (HCPs), healthcare organizations (HCOs), and others in the marketplace.
- Interactions covered include scientific discussions, promotional activities, business courtesies, educational items, fee-for-service arrangements, sponsorships, and grants.
Key Risk Areas
- Anything of Value: Bribes can take various forms beyond cash, including gifts, meals, donations, loans, travel, or employment opportunities.
- Prohibition on Use of Personal Funds: Employees cannot use personal funds to circumvent the policy's restrictions.
- Transparency: Interactions and benefits granted must be conducted openly and transparently.
- Travel: Providing travel to government officials or HCPs requires careful consideration and advanced written approval from Compliance.
- Gifts, Meals, and Hospitality: Gifts, meals, and hospitality must be modest, infrequent, comply with applicable laws, and be such that public disclosure wouldn't embarrass Agios. Lavish items are prohibited.
- Third-Party Representatives: Agios employees must ensure that third-party representatives abide by the policy and undergo appropriate due diligence.
- Regulatory Approvals: All grants, sponsorships, and support provided to organizations and institutions, including patient advocacy groups and early access programs, must comply with the Global Policy on Funding and In-Kind Support of External Organizations.
- Compliance Handbooks: Each Compliance Handbook sets out requirements for complying with applicable local laws and industry guidelines. Employees are expected to comply with the strictest requirement in case of conflicts.
Reporting Violations
- Any suspected violation of the policy must be reported to a manager, HR, Compliance, or Legal.
- Anonymous reports can be made through the Agios Compliance Helpline.
- Retaliation for reporting suspected violations in good faith is prohibited.
Training
- Agios employees undergo periodic training covering anti-corruption and anti-bribery laws, policies, and procedures.
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Description
Test your understanding of Agios' Anti-Corruption Policy, which emphasizes a zero-tolerance approach towards bribery and corruption. This quiz covers mandatory compliance for all stakeholders and identifies key risk areas associated with corruption. Ensure you're aware of the implications of non-compliance and the scope of the policy.
