ERM Program

In connection to our ERM program, Internal Audit assesses anti-corruption and anti-fraud management over entities throughout the world from a corruption risk perspective. Size (the number of people and sales volume) and a country’s ranking in the Transparency International Corruption Perception Index (CPI) are key to informing the risk profile of an entity. Entities identified as higher risk along with those of strategic importance to Mylan are a particular focus. Further, we monitor business activities that are deemed an elevated risk – such as HCP interactions – through established internal processes and controls. Our procedures also cover our business partners.

Mylan’s Corporate Compliance Program

Mylan’s Compliance Officer reports to the Board’s Compliance Committee and the Chief Executive Officer. Additionally, we train our team members on a variety of topics and encourage open communication through a variety of internal channels. We also have a Compliance Line in place which is operated by an external party, is available 24/7 and permits anonymous reports in all countries where permitted by law. Compliance-related matters are reviewed by our Head of Global Compliance and investigated in a timely, impartial fashion with all appropriate parties.

Key Compliance accomplishments in 2018 include:

  • Engaged an external consulting firm to conduct a compliance program effectiveness review, including relevant policy documents, processes, training materials and due diligence efforts.
  • Continued enhancement of Mylan’s employee data protection and privacy policies, processes and training to ensure compliance with the evolving Global Data Protection Regulation (GDPR) and other regulatory requirements.