CORPORATE RESPONSIBILITY STATEMENT
At Assertio Holdings, Inc. (“Assertio”), we approach corporate responsibility
in the same manner as we approach our business and our compliance program –
with an approach that is based on our four core principles (“Core Principles”) and the three
pillars (“Pillars”) that support our Core Principles.
Our Core Principles, each of which is further defined below, serve as the touchstones that
we expect to guide our employees’ actions on behalf of the Company, including with regard to
compliance with applicable laws and regulations. The Core Principles form the foundation of our
business and guide the daily interactions of all employees, including sales representatives.
Further, our sense of corporate responsibility is pursued with integrity in accordance with
applicable industry standards, laws and regulations.
The core principles that form the foundation of our business and guide the daily
interactions of all employees, including sales representatives, are as follows:
Ethically Promote Our Products
We are committed to promoting our products in an ethical manner. To ensure
compliance with this Core Principle, all sales representatives who are involved in the promotion
of a particular Company product are expected to know and understand the information in the
product’s label, and must successfully complete Company product training and compliance
training consistent with the Company’s comprehensive compliance program. In promotional
interactions with healthcare professionals (“HCPs”), consumers, or any other external party,
sales representatives are expected to communicate truthful, on-label information about Company
products, and all discussions are required to be consistent with the Company’s comprehensive
To facilitate ethical promotion of Company products, we provide thorough training to our
sales representatives to educate them on the legal and ethical principles that apply to product
promotion. We use a variety of media and communication strategies to enhance the
effectiveness of our training program. Our sales representatives are expected to comply with the
training they receive.
Preserve the Relationship between Healthcare Professionals and Patients
We believe that patient care should be based on patient needs and a HCP’s medical
knowledge and experience, and that patient care should not be improperly influenced by
individuals or entities outside of the HCP/patient relationship. Therefore, we believe our
interactions with HCPs should be focused on informing HCPs about our products, providing
scientific and educational information, and supporting medical research and education. To
ensure the integrity of medical decisions, we do not offer or provide improper inducements or
rewards to HCPs or consumers.
Ensure Patient Safety and Access to Company Products
We are committed to ensuring the safe use of our products. Safe use of medical products
may require instruction, education, training and technical support. In such instances, we provide
HCPs with educational programs and training related to our products. We also provide support
to independent external organizations that provide important educational opportunities to HCPs.
Patient access to physician prescribed medical products can be challenging. The cost of
medical products can also be financially burdensome for many patients. We support programs to
help reduce such barriers to access so patients may get the medicines their physicians determine
is most appropriate based on their medical condition.
Protect Patient Privacy
We recognize the importance of protecting patient privacy and have established policies
and requirements to avoid affirmative contact with confidential patient information (unless
patient consent is received) and to ensure appropriate handling of any confidential patient
information that our sales representatives inadvertently receive. Any business activities
involving patients or consumers are expected to be conducted in accordance with applicable
industry standards, laws, and regulations, and the Company’s comprehensive compliance
Our commitment to corporate responsibility, both in our business and in our compliance
program, is supported by the Pillars described below. Our training programs and
organizational structures have been developed to enable everyone to understand the Pillars and
how to implement them to support our Core Principles.
We are inspired by patients. This inspiration motivates us to develop and make available
high-quality medicines that help people live longer, healthier lives. We continually challenge
ourselves to meet and exceed the highest standards of performance, integrity and compliance.
By endeavoring to always putting patients first, we believe we can ensure that we can meet the
high standards we aspire to achieve.
Ethical and Responsible Interactions with Healthcare Professionals
Ethical and responsible relationships with HCPs are critical to our mission of helping
patients by developing and marketing needed medicines. In order for HCPs to make the right
choices for their patients and achieve positive health outcomes, we believe it is important that
HCPs understand the attributes of available treatment options. An important part of achieving
our mission is to ensure that in our interactions with HCPs, we provide information about the
risks and benefits of our products and their role in patient healthcare. We have developed
compliance policies and employee training programs that provide guidance on appropriate
interactions with HCPs and emphasize adherence to applicable laws and regulations for all
employees who market our products.
Tone at the Top
Our leaders and managers are responsible for establishing and maintaining our culture
and integrating that culture into everything we do. The tone at the top reinforces our guiding
values and ethical culture. Properly nurtured, we believe that this corporate value is the
foundation upon which the culture of our company is built.
We are committed to conducting business with the highest degrees of integrity,
professionalism and social responsibility. We are also committed to complying with all of the
laws, regulations, and industry codes of conduct that apply to our business.