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Deborah Penza Chief Compliance Officer Watson Pharmaceuticals Inc.

Starting a Compliance Program From Scratch. Deborah Penza Chief Compliance Officer Watson Pharmaceuticals Inc. Starting a Compliance Program From Scratch. Code of Conduct What it is, and what it isn’t Hierarchy of corporate documents. Starting a Compliance Program From Scratch.

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Deborah Penza Chief Compliance Officer Watson Pharmaceuticals Inc.

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  1. Starting a Compliance Program From Scratch Deborah Penza Chief Compliance Officer Watson Pharmaceuticals Inc.

  2. Starting a Compliance Program From Scratch • Code of Conduct • What it is, and what it isn’t • Hierarchy of corporate documents

  3. Starting a Compliance Program From Scratch • Code of Conduct • Principles-based vs. policy-based Code • Avoid legalese, and ensure the Code is written at the appropriate reading level for your employee population

  4. Starting a Compliance Program From Scratch • Code of Conduct • In addition to general topics, be sure to address identified risks specific to your organization and industry • Include a discussion on non-retaliation and employees’ obligation to report potential violations

  5. Starting a Compliance Program From Scratch • Code of Conduct • Who will review and approve the Code? • Executive team • Board of Directors • How often?

  6. Starting a Compliance Program From Scratch • Code of Conduct • Other considerations to make: • Paper vs. electronic • Language translations • Works Council approvals

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