Corporate Compliance
At Spectrum, we are committed to a corporate culture of compliance and integrity.
Our Compliance and Ethics Program is a set of internal controls and standards that promote adherence to pharmaceutical industry statutes, regulations, and requirements of the federal health care programs with respect to the development, manufacturing, marketing and selling of products.
Our Commitment
We foster an environment that promotes the prevention, detection and resolution of any regulatory or ethical challenges. Through the Compliance and Ethics Program, we provide adequate resources, a timetable for the implementation of the compliance measures, and the identification of an individual to serve as a Chief Compliance Officer to ensure that each of the recommended and adopted elements are addressed. Led by the example of the Board of Directors and senior management, all Spectrum employees, partners and other third-party contractors are responsible for adhering to the Compliance and Ethics Program.
Code of Business Conduct and Ethics
Spectrum’s foundation is built on strong ethical principles and values which reflect our commitment to conducting business with honesty, fairness and integrity; whereby we avoid doing anything that could even suggest impropriety in any of our dealings.
Spectrum abides by the following core principles:
- We will use all lawful and ethical means possible to bring our therapy options to the right patients, in the right way.
- We will be personally responsible to understand and adhere to the letter and spirit of all laws and company policies that pertain to our daily business.
- We will partner only with healthcare professionals, suppliers and other business partners who share our commitment to understand and uphold the laws and regulations that apply to our operations.
- We will respect and protect the dignity and privacy of patients, healthcare professionals and their staff, business partners, competitors and our fellow employees.
- We will promptly and cooperatively report without fear of retaliation any behavior contrary to these principles to management, the Compliance Department or the Compliance Helpline.
| You may contact Spectrum's Compliance Officer at any time at: compliance@sppirx.com |
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| Notice of Compliance |
| Compliance Program |
| Employee Code of Business Conduct and Ethics |
| Vendor Code of Business Conduct and Ethics |
Elements of the Program
Governance
The Spectrum Pharmaceuticals, Inc. Compliance and Ethics Program is overseen and managed by the following committees and officers:
- Chief Compliance Officer
- Compliance Committee
- Funding and Support Request Review Committee
- Chief Legal Officer
Written Standards
Spectrum is committed to developing and distributing written standards of conduct, as well as written policies and procedures that verbalize the Company’s commitment to compliance (e.g., by including adherence to the Compliance and Ethics Program as an element in evaluating management and employees) and addressing specific areas of potential fraud and abuse, such as the reporting of pricing and rebate information to the federal healthcare programs and sales and marketing practices.
Education and Training
Spectrum is committed to developing and implementing regular, effective education and training programs for all affected employees and third parties. At Spectrum, training and education enables individuals to recognize their obligations to comply with the organization’s policies and procedures and identify high risk areas, which reduces the probability of non-compliant conduct. Our training curricula are tailored to an individual’s role within the organization. Employees are not permitted to conduct any activities without prior training codified in a documented training record.
Communications
Spectrum is committed to creating and maintaining an effective line of communication between the Chief Compliance Officer and all employees, including a process (such as a Helpline or other reporting system) to receive complaints or questions, and the adoption of procedure to protect the anonymity of complainants and to protect whistleblowers from retaliation.
If you wish to report a compliance issue, you can call the Compliance Helpline on:
1-844-587-1660
or visit: www.sppirx.ethicspoint.com
Risk Assessments, Auditing and Monitoring
Spectrum is committed to using audits and/or other risk evaluation techniques to monitor compliance, identify problem areas and assist in the reduction of identified problems.
Discipline and Due Diligence Screening
Spectrum is committed to developing policies and procedures addressing the non-employment or retention of individuals or entities excluded from participation in federal health care programs and enforcing appropriate disciplinary action against employees or third parties who have violated company policies and procedures and/or applicable federal health care program requirements.
Investigations
Spectrum is committed to developing policies and procedures for the investigation of identified instances of noncompliance or misconduct. These include directions regarding the prompt and proper response to detected offenses, such as the initiation of appropriate corrective action and preventive measures and processes to report the offense to relevant authorities in appropriate circumstances. At Spectrum, the facts and circumstances of each situation undergo a thorough review and violations are addressed in an appropriate manner.
Transparency and Disclosure
Spectrum is committed to reporting all transactions that constitute a payment or transfer of value to a healthcare professional (HCP) or healthcare organization (HCO). At Spectrum, it is the responsibility of each employee to track all applicable transactions, regardless of whether the employee is seeking reimbursement for expenses. Individual employees may be held financially responsible for any Company penalties incurred as a result of the individual employee failing to report or inaccurately reporting a transaction to the Company. If an individual is ever in doubt as to whether a payment or transfer of value should be reported, they should err on the side of reporting.
Contact Spectrum's Compliance Officer at compliance@sppirx.com.