Driving a Compliant Workforce
Our Staff are evaluated equally on performance and on behaviors. These behaviors are tied to our company values and leadership attributes which apply to all staff around the globe, and which explicitly include being ethical in all activities. These behaviors are reinforced with training and monitored through compliance processes.
Incentivizing Appropriate Promotional Interactions
All our staff are evaluated equally on performance (as measured against annual goals) and on behaviors. These behaviors are tied to our company values and leadership attributes, which apply to all staff around the globe, and which explicitly include being ethical in all activities. In addition, our remuneration of sales representatives is regularly reviewed and aligned with compliant marketing practices. Sales representatives are not incentivized to promote off-label use and are strictly prohibited from doing so by compliance policies and regular training. We strive for a balanced mix of sales incentives and fixed compensation (e.g., base salary) for our sales force in an effort to reward successful sales execution while also supporting compliance with appropriate selling behaviors. Incentives are typically calculated using business performance as the objective measure for effectiveness of customer engagement, clinical education, and logistical support around product access and patient services. On an annual basis, management, working with an independent compensation consultant to the Compensation and Management Development Committee of the Board of Directors, conducts a review of the Company’s compensation policies and practices for all staff members generally, and for our staff members who participate in our sales incentive compensation program.
All global staff and contractors are trained annually on Amgen’s Code of Conduct, which addresses appropriate interactions with the healthcare community and the prevention of compliance issues. Due to their proximity to the healthcare community, field staff, in both sales and medical roles, take the annual Code of Conduct training as well as targeted additional training on policies, restrictions and rules applicable to their roles and areas of specialization. They also receive additional training on product specific information, disease state, and therapeutic area.
Addressing violations of standards and regulations
Ensuring appropriate communications requires that we have a vigorous process to identify errors, misconduct, or other challenges to the accuracy of Amgen communications. At Amgen, we have a developed multiple channels to identify and investigate issues, and receive and address complaints from the public, government agencies and healthcare professionals regarding our advertising and promotional activities. In the U.S., all FDA findings related to marketing are available publicly in the FDA Data Dashboard while our business conduct hotline is available on our website for the public and healthcare community. In other geographies, complaints can be filed with local offices.
We also have a business conduct hotline established that allows our employees and third parties to anonymously report potential compliance violations. If our marketing or advertising rules of conduct are broken, we have a working committee in place to take immediate countermeasures. Any violations are dealt with using appropriate corrective action up to and including termination of employment.
As of August 4, 2023