Anti-Corruption Policy Quiz

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Questions and Answers

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?

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?

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?

Consultants, vendors, suppliers, and agents Signup and view all the answers

What unique risks does Agios face in its sector?

Anti-corruption risks Signup and view all the answers

Which type of interactions requires careful attention under the Anti-Corruption Policy?

Engaging with healthcare professionals and government officials Signup and view all the answers

What can happen if Agios does not comply with anti-corruption laws?

Reputational damage and penalties Signup and view all the answers

Who is responsible for ensuring that third-party representatives comply with the Anti-Corruption Policy?

Agios employees overseeing those representatives Signup and view all the answers

What is the main purpose of the policy outlined in the content?

To ensure compliance with anti-bribery and anti-corruption laws. Signup and view all the answers

Who is required to comply with this policy?

All Agios employees globally. Signup and view all the answers

Which of the following interactions is mentioned as applicable under the policy?

Scientific discussions with Healthcare Organizations. Signup and view all the answers

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

Report it to their manager, HR, Compliance, or Legal. Signup and view all the answers

What types of activities are considered interactions under this policy?

Meetings with government officials. Signup and view all the answers

What is the stance of Agios regarding retaliation for reporting suspected violations?

Agios explicitly prohibits retaliation against good faith reporters. Signup and view all the answers

Where can anonymous reports of violations be made?

Through the Agios Compliance Helpline or website. Signup and view all the answers

The policy is intended to be read in conjunction with which of the following?

The Global Policy on Interactions with Healthcare Professionals. Signup and view all the answers

What is the primary responsibility of Agios employees regarding the global policy?

To comply with the policy and applicable Compliance Handbooks Signup and view all the answers

How should the training schedule for Agios employees be determined?

By Compliance, following industry standards Signup and view all the answers

In the event of a conflict between the global policy and an applicable law, which standard should Agios employees comply with?

The strictest standard Signup and view all the answers

Which of the following is prohibited under Agios's Anti-Corruption Policy?

Bribery and other corrupt conduct Signup and view all the answers

Who are included in the key risk areas for the prohibition against bribery?

Healthcare professionals (HCPs), government officials, and competitors Signup and view all the answers

What does the global policy state about the ownership of the Compliance Handbook?

It is confidential and proprietary to Agios Signup and view all the answers

Which laws are highlighted as significant in the enforcement of anti-corruption policies?

Laws such as the FCPA Signup and view all the answers

What type of conduct is Agios’s Anti-Corruption Policy specifically concerned with?

Bribery, kickbacks, and improper inducements Signup and view all the answers

What is classified as a bribe or kickback?

Items of value that induce a person to violate loyalty to their employer. Signup and view all the answers

When can travel expenses be provided to a Government Official or HCP?

Only if the travel has been pre-approved and is for a legitimate business purpose. Signup and view all the answers

What must Agios employees do before providing any travel to a Government Official or HCP?

Consult with the Compliance Department for written approval. Signup and view all the answers

What criteria must be met for travel expenses to be approved?

Travel must be reasonable, necessary, and without family members accompanying. Signup and view all the answers

What aspect of interactions with Government Officials and HCPs is emphasized?

They must be conducted in a transparent manner. Signup and view all the answers

Under what condition can personal funds be used by Agios employees?

Only under an approved fee-for-service agreement. Signup and view all the answers

What is a risk associated with accepting gifts or entertainment from HCPs?

It can create a public appearance of favoritism. Signup and view all the answers

Why must benefits to HCPs and Government Officials be approached with caution?

They can violate loyalty principles and lead to ethical violations. Signup and view all the answers

What is the highest risk associated with third-party representatives?

When they engage with Government Officials or HCPs Signup and view all the answers

What must be ensured regarding any gifts, meals, or hospitality provided by Agios?

They must comply with applicable laws and policies Signup and view all the answers

What is prohibiting regarding Agios' employees and third-party representatives?

They cannot use third-party representatives to bypass company policies Signup and view all the answers

What type of agreement must contractors or third parties have when engaged by Agios?

A written agreement containing anti-corruption compliance provisions Signup and view all the answers

What is the stance on lavish meals and gifts provided by Agios?

They are prohibited and must always be modest Signup and view all the answers

What must be done before providing gifts, meals, or hospitality to Government Officials?

Prior written approval by Compliance is required Signup and view all the answers

What criteria must Agios’ third-party representatives meet in their business conduct?

They must conduct business ethically, consistent with Agios' principles Signup and view all the answers

What is required to support third-party representatives acting on behalf of Agios?

Risk-based due diligence must be conducted Signup and view all the answers

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.