A global pharmaceutical giant with a presence in over 50 countries and nearly 50,000 employees produces tens of billions of tablets and capsules every year in its manufacturing facilities, and is a leading global supplier of active pharmaceutical ingredients. To support its mission of increasing access to high-quality health care, the company offers one of the most extensive generic drug lines in the industry. The company puts equal importance on the health and well-being of its own employees, and offers a wide range of options to ensure an appropriate work-life balance.
Despite its size, the company lacked a strong culture of compliance, and had no systems in place to manage information about how, when and where their resources were being deployed around the globe. Further, they lacked robust third-party risk and compliance analytics. This lack of governance was causing real problems within the company, which was being investigated to confirm compliance with the Foreign Corrupt Practices Act (FCPA) in Latin America and needed to be able to provide evidence.
WHAT THE TEAM DID
Grant Thornton LLP provides support across multiple platforms, having grown its relationship with the company significantly since its inception several years ago. Because of this, our team was in a strong position to help the company strengthen its compliance function.
In building the relationship, our teams had worked with key areas of the company:
Commercial: Grant Thornton was originally brought in to work with the commercial side of the company on creating a customer relationship management (CRM) strategy using a people, products and technology perspective. The team spent several weeks analyzing call center information and identifying areas where the service representatives could improve. This quickly established the need to fold in the company’s whole sales organization and marketing department if an effective strategy was to work across the company. After crafting a solid plan, the team presented the company with a three-year roadmap with six specific projects in place to better manage the CRM process.
Generic: We identified the need for the company to put a portal in place for national account managers who worked on the generic drug side of the business to be able to quickly identify where and how their product was arriving at retailers and wholesalers. Working with the company’s IT department, our team designed the portal to help streamline the information for the sales force.
Regulatory: As our teams were working on the commercial and generic sides of the business, our Forensic Investigative Dispute Services group was engaged by the company’s chief compliance officer (CCO) to build out a global compliance function and global third-party program. The team built out the compliance education program for the whole company, which was being investigated to confirm adherence to the FCPA.
For the compliance work, we conducted a third-party due diligence audit using two years’ worth of company data. We looked at three levels of compliance and risk that are related to third parties:
- Transactions that were already on the company’s books
- Confirming that the third party’s books matched the company’s books
- Identifying high-risk third parties that required an on-the-ground compliance program
The team’s advanced analytic skills helped us to gain insight into these three levels of compliance and risk. Digging into the data, we were able to identify current risk areas and risks that were likely to arise in the future. We then applied that knowledge to existing company data and were able to show the CCO how using our program could supply him with the business insights that the company so badly needed.
As a result of this work, the company is now rolling out a global transparency reporting requirement, using our data-driven approach as a guide to help them effectively deploy their resources and avoid regulatory violations.
Over the course of their relationship with Grant Thornton, with the realizations about how regulatory requirements affected their business, the company has drastically changed their culture in terms of compliance. The CCO — who came from the global internal audit side of the company’s business — continues to steer the company in the right direction in terms of compliance, risk and third-party relationships, and our Grant Thornton teams continue to grow their relationship with the company.
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