Our Comprehensive Compliance Program is one of the key components of our commitment to the highest standards of corporate conduct and has been tailored to fit the unique environment of our company. Our Compliance Program is also dynamic, and we regularly review and enhance our Compliance Program to meet our evolving compliance needs.
LEADERSHIP AND STRUCTURE
- Compliance Officer. We have designated a senior-level official in our organization to serve as our corporate compliance officer. We are committed to our Compliance Officer having the ability to effectuate change within the organization as necessary and to exercise independent judgment. Our Compliance Officer is charged with the responsibility for developing, operating, and monitoring the Comprehensive Compliance Program.
- Compliance Committee. Incyte has established a Compliance Committee to advise the Compliance Officer and assist in the implementation of the Compliance Program.
Incyte’s Code of Business Conduct and Ethics (the "Code") is our statement of ethical and compliance principles that guide our daily operations. The Code establishes that we expect management, employees, and agents of the company to act in accordance with law and applicable company policy. The Code articulates our fundamental principles, values, and framework for action within our organization.
EDUCATION AND TRAINING
A critical element of our Compliance Program is the education and training of our employees on their legal and ethical obligations under applicable federal healthcare program requirements. Incyte is committed to taking all necessary steps to effectively communicate our standards and procedures to all affected personnel. Moreover, Incyte will regularly review and update its training programs, as well as identify additional areas of training on an "as needed" basis.
INTERNAL LINES OF COMMUNICATION
Incyte is committed to fostering dialogue between management and employees. Our goal is that all employees, when seeking answers to questions or reporting potential instances of fraud and abuse, should know whom to turn to for a meaningful response and should be able to do so without fear of retribution. To that end, we have adopted open-door policies, as well as confidentiality and non-retaliation policies.
In addition, Incyte also has a Helpline that provides a means for employees or external parties to report a compliance concern or misconduct. This Helpline is managed by a third-party vendor and provides the option to report anonymously as permitted by local law.
AUDITING AND MONITORING
Incyte’s Compliance Program includes efforts to monitor, audit, and evaluate compliance with the company’s compliance policies and procedures. The nature of our reviews as well as the extent and frequency of our compliance monitoring and auditing varies according to a variety of factors, including new regulatory requirements, changes in business practices, and other considerations.
RESPONDING TO POTENTIAL VIOLATIONS
Incyte’s Compliance Program includes clear disciplinary policies that set out the consequences of violating the law or company policy. Although each situation is considered on a case-by-case basis, we will consistently undertake appropriate disciplinary action to address inappropriate conduct and deter future violations.
CORRECTIVE ACTION PROCEDURES
Our Compliance Program requires the company to respond promptly to potential violations of law or company policy, take appropriate disciplinary action, assess whether the violation is in part due to gaps in our policies, practices, or internal controls, and take action to prevent future violations.