Distributor Compliance Program
Foundational to Alcon’s success is our belief and commitment to doing business right. Part of this strategy includes ensuring great Compliance Programs are established and enforced by our distributors based on their size, resources and activities. Here are tools and resources that enable us to do business right so we can continue to help people around the world see brilliantly.
You may use all of the resources or select the ones that pertain to your business. Due to local law, regulation and trade association code requirements, some of these resources may require modifications. If modifications are required, you may need to review these templates with your legal advisors before implementing them.
Below, you will find templates and materials for each of your main risk areas to help you formalize a new Compliance Program or elevate an existing one. The downloadable assets are available in 18 languages.
Design and adopt a Code of Conduct for your organization with the below templates and instructions. Alcon expects an effective Code of Conduct includes provisions relating to Anti-bribery, Anti-corruption, Conflict of Interest and Fair Dealing. Refer to the Quick Reference Guides (QRGs) and the Learning Program for Compliance guidelines to facilitate employee training on Anti-bribery topics.
Disclose actual or potential conflicts of interest in a timely and effective manner, or document the decision made on how the matter is to be resolved, with this template. Refer to the QRG for Compliance guidelines to facilitate employee training on Conflict of Interest.
Design and adopt various procedures related to interactions with Health Care Professionals (HCPs) and Government Officials, with the below templates and guidelines.
Each procedure is accompanied by a QRG that serves as an excerpt of Alcon’s comprehensive policy “The Lens” and is designed to help you to understand Alcon’s requirements within the area. The QRGs can be used to facilitate employee trainings on the various topics.
Distributor Organized Events
Funding Third Party Events
Demonstration and Evaluation Products
Design and adopt procedures to ensure proper documentation practices are in place for your organization with the below template and guidelines. The QRG contains Compliance guidelines to facilitate employee training on Good Books & Records.
Use the template to support and document business travel, meetings and expenses related to interactions with HCPs, customers or potential customers.
Inform your employees of the ways they can speak up and report potential violations of law or unethical business practices with the below template.
Alcon’s guidelines for performance of proper due diligence connected to sub-contractors in the fulfillment of the distribution agreement.
Evaluate your organization’s compliance program with the below Self-Assessment Tool. It will allow you to better understand the existing compliance program and highlight potential opportunities and areas for improvement.
Document compliance training provided to your employees with the below template. This form can be used for multiple trainings, such as training on Code of Conduct, Conflict of Interest, Interactions with HCPs & Government Officials, Keeping Good Books & Records, Reporting a Concern, or Sanctions, Boycotts & Money Laundering.
Inform Third Parties who deal with Alcon products (i.e., promotion, destruction, or handling) about vigilance requirements with the below template contract language.
Important note:Each of these procedure templates require modification and adjustments (where highlighted in yellow) in order to be used properly, given that local laws, regulations, or trade association codes may include additional or different requirements.
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