Partner Therapeutics’ Healthcare Compliance Program
Partner Therapeutics Inc. (“PTx” or the “Company”) is committed to essential principles of good corporate conduct and integrity in all of its activities. To that end, PTx has established and will maintain an effective Compliance Program to support the acquisition, development, and commercialization of medically important pharmaceutical products.
The key components of the Compliance Program address each of the seven elements of an effective compliance program as outlined in the Compliance Program Guidance for Pharmaceutical Manufacturers issued in 2003 by the Office of the Inspector General of the Department of Health and Human Services (“OIG Guidance”), as well as consideration of the Pharmaceutical Research and Manufacturers of America Code on Interactions with Health Professionals as updated and made effective January 2009 (PhRMA Code), the Prescription Drug Marketing Act, relevant guidelines of the American Medical Association (AMA), the guidelines for the Accreditation Council for Continuing Medical Education (ACCME), and other guidance put issued by the US Food and Drug Administration (FDA) and other government agencies.
As the OIG Guidance envisions, PTx has designed its Compliance Program to fit the size, resources, market position, and other unique aspects of our Company. PTx also recognizes that an effective compliance program must evolve and respond to the changing circumstances of the Company and the compliance, legal and regulatory environment. PTx is committed to continuous quality improvement based on regular review, assessment, and development of the Compliance Program.
For more information on compliance at PTx, please send an email to email@example.com.
Annual Declaration of Compliance with California Health & Safety Code §119402
Affirmed as of January 1, 2020
California Health and Safety Code §119400-119402 (the “California Act”) requires pharmaceutical companies to adopt a Comprehensive Compliance Program in accordance with the OIG Guidancel, as well as to develop policies for compliance with the PhRMA Code.
PTx is committed to conducting its business ethically and in compliance with all applicable laws and has established a Compliance Program in accordance with the California Act.
PTx has established a maximum annual aggregate dollar limit of $2,500 for gifts, promotional materials or items or activities provided to California health care professionals. This dollar limit is a maximum only and does not necessarily represent a typical, average, usual or customary amount.
The annual spending limit does not apply to the following:
Drug samples given to physicians and other HCPs intended for free distribution to patients;
Financial support for continuing medical education forums;
Financial support for health educational scholarships; or
Payments for legitimate professional services, including, but not limited to consulting.
To the best of its knowledge, and based upon a good faith understanding of the statutory requirements of the California Act, PTx declares that it is in compliance with its Compliance Program.