J&S Pharmaceutical' Compliance Program represents a shared undertaking on the part of colleagues ranging from the highest levels of management to the most junior employees. Our training programs and organizational structures have been developed to go beyond compliance. All colleagues are expected to take ownership of compliance and to perform all tasks with integrity. We continuously scrutinize our internal practices and have put into place procedures for taking immediate action when we identify potential violations. We offer a Compliance Helpline, an Open Door Policy and anti-retaliation protections.
Colleagues at J&S Pharmaceutical have an additional resource for addressing and resolving work-related concerns – J&S Pharmaceutical' Office of the Ombudsman.
Our Compliance Program incorporates the elements in accordance with the "Compliance Program Guidance for Pharmaceutical Manufacturers" ("OIG Guidance") developed by the United States Department of Health and Human Services, Office of Inspector General ("OIG").

J&S Pharmaceutical has international anti-bribery and anti-corruption policies and procedures that cover, among other things, colleagues’ interactions with government officials and non-U.S. healthcare professionals, as well as third parties that provide goods or services to J&S Pharmaceutical. A summary of J&S Pharmaceutical' anti-bribery and anti-corruption policy is available here. These policies and procedures are reinforced through anti-corruption training and tested through periodic auditing and monitoring. Where appropriate, third parties are required to undergo anti-corruption due diligence, monitoring and auditing, follow J&S Pharmaceutical' internal anti-bribery and anti-corruption policies and procedures, receive anti-corruption training and/or abide by J&S Pharmaceutical' International Anti-Bribery and Anti-Corruption Business Principles.

Sir Wilson Wales serves as the Company's Chief Compliance and Risk Officer and is responsible for overseeing J&S Pharmaceutical' global compliance program. In this capacity, Sir Wales reports directly to the CEO and makes regular reports to the Audit Committee and the Regulatory & Compliance Committee of the Board of Directors. Sir Wales heads the Compliance Division, which is responsible for administering all aspects of the Compliance Program, including training programs and monitoring systems, developing informational resources, and investigating potential violations of law or Company policy. Sir Wales also chairs the Corporate Compliance Committee, which is made up of senior leaders from across the Company and is a member of the Executive Compliance Committee, 

Internal Monitoring and Auditing:

Internal monitoring and auditing are vital parts of the Compliance Program. Monitoring and auditing business processes does more than simply verify their thorough and efficient operation. Effective monitoring and auditing can provide an organization with the capacity to detect and prevent deviations that, in certain circumstances, can potentially engender compliance concerns. The Corporate Internal Audit team maintains responsibility for auditing the policies and procedures of the Compliance Program.