To ensure compliance with the laws, industry guidelines, and Galderma standards applicable to the development, manufacturing, marketing, and sale of our products, the Company established a Comprehensive Compliance Program (CCP) that is consistent with the Department of Health and Human Services Office of Inspector General Guidance. Our CCP takes into consideration the nature of our business, whether it be prescription drugs, medical devices or consumer products, and is one of the key components of our commitment to the highest standards of conduct.
The Galderma CCP, comprised of Galderma's Global Code of Ethics, the U.S. Code of Conduct and Compliance Manuals, summarizes the ethical and legal standards to which all Galderma employees must adhere. Our CCP is dynamic; we regularly review and enhance our CCP to meet our evolving compliance needs. The purpose of our CCP is to prevent and detect violations of law or Company policy. As HHS-OIG calls for in its Guidance, we have tailored our CCP to fit the unique environment of our Company. The Company has designated compliance personnel, including a Compliance Officer, with responsibility for developing, operating, monitoring, and enforcing this program. The Compliance Officer or designee makes periodic reports to the Compliance Committee and reports significant issues directly to the President of the Company and the U.S. Leadership Team. The Company provides a toll-free telephone line to report suspected violations of Company policies or laws. Calls can be made anonymously and without fear of retribution 24 hours a day, seven days a week. Allegations of non-compliance are documented and investigated so that appropriate corrective action can be taken when warranted.
Comprehensive Compliance Program
California Transparency in Supply Chains Act of 2010