Comprehensive Compliance program

Description

I. Introduction

General
Novartis Vaccines and Diagnostics, Inc. ("Novartis V&D") formerly the Chiron Corporation ("Chiron"), is committed to establishing and maintaining an effective Integrity and Compliance Program in accordance with "Compliance Program Guidance for Pharmaceutical Manufacturers," published by the Office of Inspector General, U.S. Department of Health and Human Services (the "HHS-OIG Guidance"). Our Integrity and Compliance Program is one of the key components of our commitment to the highest standards of corporate conduct.

Transition, Chiron and Novartis merger
On April 20, 2006, Chiron Corporation was acquired by merger and became an indirect wholly-owned subsidiary of Novartis AG, a Swiss corporation, and is now known as Novartis Vaccines and Diagnostics, Inc or Novartis V&D.

Purpose
The purpose of our Integrity and Compliance Program is to prevent and detect violations of law or company policies. As the HHS-OIG Guidance recognizes, however, the implementation of such a program cannot guarantee that improper employee conduct will be entirely eliminated. Nonetheless, it is our expectation that employees will comply with our Code of Conduct, and the policies established in support of such a Code. In the event that we become aware of violations of law or company policy, we will investigate the matter and, where appropriate, take disciplinary action and implement corrective measures to prevent future violations.

Described below are the fundamental elements of the Novartis V&D Integrity and Compliance Program. As HHS-OIG calls for in its Guidance, we have tailored our program to fit the unique environment of our company. Moreover, our Integrity and Compliance Program is dynamic; we regularly review and enhance our program to meet our evolving compliance needs.

 

II. Overview of Compliance Program

Leadership and Structure
Compliance Officer, and maintains overall responsibility for the global Novartis V&D Integrity & Compliance program. Ms. Leader reports directly to Andrin Oswald, CEO of Novartis V&D.

Ann Beasley Bacon is the designated senior-level official serving as the Vice President of Integrity and Compliance with daily responsibility for developing, operating and monitoring the Novartis V&D Integrity and Compliance Program. Ms. Bacon reports directly to Ms. Leader and either can be reached at:

NVD.IntegrityCompliance@Novartis.com

 

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