Anti-Bribery and Anti-Corruption Policy

1. Introduction and Purpose

The CPD Network Association ("CPD Network") is committed to conducting all business activities with integrity and in compliance with applicable laws, regulations, and ethical standards.[1][2] This Anti-Bribery and Anti-Corruption Policy ("Policy") demonstrates our commitment to preventing bribery and corruption in all our activities, including medical education programs.

This Policy applies to all employees, directors, officers, volunteers, contractors, and third parties acting on behalf of the CPD Network.

The purpose of this Policy is to:

Establish clear standards for ethical conduct
Provide guidance on identifying and avoiding bribery and corruption
Ensure compliance with applicable anti-bribery laws[7]
Protect the CPD Network's reputation and integrity
Maintain public trust in our educational mission

2. Scope

This Policy applies to all CPD Network activities worldwide, including but not limited to:

Medical education program development and delivery
Research activities and publications
Partnerships with pharmaceutical companies, medical device manufacturers, and other healthcare organizations
Relationships with healthcare professionals and institutions
Government and regulatory interactions
Charitable and educational activities

All individuals covered by this Policy must understand and comply with these standards.

3. Definitions

Bribery: The offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action that is illegal, unethical, or a breach of trust.[5]
Corruption: The abuse of entrusted power for private gain, including bribery, extortion, and fraud.[6]
Anything of Value: Money, gifts, entertainment, hospitality, employment, services, or any other benefit.
Government Official: Any person holding a legislative, administrative, or judicial office, including employees of government agencies and state-owned enterprises.
Healthcare Professional (HCP): Any individual qualified to prescribe, purchase, recommend, or administer medical products or services.
Facilitation Payment: Small payments made to secure or expedite routine government actions.
Third Party: Any individual or organization acting on behalf of the CPD Network, including agents, consultants, distributors, and joint venture partners.

4. Policy Statement

The CPD Network maintains a zero-tolerance policy toward bribery and corruption. We are committed to conducting business ethically and in compliance with all applicable laws and regulations.

We commit to:

Maintaining the highest standards of integrity in all our activities
Ensuring transparency in our financial transactions and reporting
Implementing robust internal controls and monitoring systems
Providing regular training and education on anti-bribery and anti-corruption
Conducting due diligence on all business partners and third parties
Promptly investigating and addressing any suspected violations

5. Prohibited Conduct

The following activities are strictly prohibited:

Offering, promising, or giving bribes to any person or organization
Accepting or soliciting bribes from any person or organization
Making facilitation payments to government officials
Engaging in any form of corruption or fraudulent activity
Offering inappropriate gifts, entertainment, or hospitality
Making charitable contributions to influence business decisions
Providing anything of value to healthcare professionals to influence prescribing or purchasing decisions
Participating in kickback arrangements or other corrupt practices

Note: Facilitation payments are prohibited regardless of local customs or practices.

6. Gifts, Hospitality, and Entertainment

Gifts, hospitality, and entertainment must be modest, reasonable, and provided or accepted only for legitimate business purposes. They must not create an appearance of impropriety or influence medical education decisions.

Guidelines:

Gifts are not permitted for any members of the organizations leadership or to any official stakeholders
Prohibited for Government Officials or HCPs if intended to influence prescribing or educational content[3][4]
Hospitality (e.g., meals during meetings) must be reasonable and related to educational activities
In the pharmaceutical context, interactions must align with industry codes prohibiting inducements to HCPs[3]

All gifts and hospitality exceeding $50 CAD in value must be pre-approved by the (co)-Directors.

Special care must be taken when dealing with pharmaceutical companies and medical device manufacturers, as these relationships are subject to additional regulatory requirements.

7. Charitable Contributions and Sponsorships

Charitable contributions and sponsorships must be legitimate and transparent, not used to circumvent anti-bribery laws or to improperly influence business decisions.

Must be made to legitimate charitable organizations
Must be properly documented and transparent
Must not be conditional on business decisions
Must comply with all applicable laws and regulations
Must be approved by the (co)-Directors
Must not be made to organizations controlled by government officials or business partners

8. Third Party Relationships

The CPD Network is responsible for the actions of third parties acting on our behalf. All third-party relationships must be properly managed and monitored.

Conduct due diligence before engaging third parties
Include anti-bribery and anti-corruption clauses in all contracts
Provide training on this Policy to relevant third parties
Monitor third-party activities and compliance
Maintain records of all third-party relationships
Report any suspected violations immediately

9. Record Keeping and Financial Controls

Accurate record keeping is essential for demonstrating compliance with this Policy and applicable laws. All financial transactions must be properly recorded and supported by appropriate documentation.

10. Reporting Violations and Concerns

All employees and third parties are required to report any suspected violations of this Policy or applicable laws immediately.

Direct supervisor or manager
(co)-Directors
Anonymous reporting hotline (if available)
Email to [email protected]

All reports will be investigated promptly and thoroughly. The CPD Network prohibits retaliation against anyone who reports suspected violations in good faith.

11. Training and Education

All employees and relevant third parties must receive regular training on this Policy and applicable anti-bribery and anti-corruption laws. Training will be provided upon initial engagement and annually thereafter.[8]

12. Consequences of Non-Compliance

Violations of this Policy may result in disciplinary action, including termination of employment or contract, and may also result in criminal prosecution and civil penalties under applicable laws.

13. Policy Review and Approval

This Policy will be reviewed annually or as needed by the Board of Directors.

Contact Information

For questions about this Policy or to report concerns, please contact us using the information below.