Indivior has put in place a comprehensive compliance approach to help ensure that all of its business activities are conducted in a responsible and compliant manner via the Global Indivior Integrity and Compliance Program (ICP). It is administered by a team of over twenty people led by Indivior’s Chief Integrity & Compliance Officer who is a member of the Executive Committee. Its operational methods have evolved in a cross-functional manner through integrated ownership and oversight at all levels across Indivior’s departments.
In January 2019, Indivior established the Compliance Committee, which is chaired by the Chief Integrity & Compliance Officer. It comprises all of the members of the Executive Committee and meets monthly. It is responsible for supporting the Chief Executive Officer and Chief Integrity & Compliance Officer with the administration of the ICP and overseeing compliance with applicable laws, rules and regulations related to Indivior’s business operations excluding compliance with securities regulation and financial reporting requirements.
Another important ICP element is the Compliance Champion Program. Its objective is to integrate and expand the compliance footprint within Indivior by training specific workforce members to act as support within their business unit or function to address the first line of compliance.
The ICP applies a ‘Learn, Adjust and Prevent’ approach and has a multi-year strategy to guide continuous evolution.
Key ICP elements are;
- Optimization of written policies, procedures and standards of conduct
- Administration of the ICP by the Chief Integrity & Compliance Officer and the Compliance Committee
- Workforce training and education
- Open lines of communication
- Annual risk assessment process
- Internal monitoring and auditing related to compliance
- Whistleblowing helpline for reporting of concerns and related reviews and internal investigation process
- Coaching and disciplinary processes
- Meeting the requirements of the 2020 Resolution Agreement
- In connection with the 2020 Resolution Agreement between Indivior Inc. and Indivior PLC and the United States Attorney’s Office for the Western District of Virginia and the United States Department of Justice’s Consumer Protection Branch, Indivior Inc.’s U.S. operations are subject to compliance measures set forth in three separate agreements:
- A Corporate Integrity Agreement with the Department of Health and Human Services Office of Inspector General (OIG);
- Compliance Measures with the Department of Justice (DOJ); and
- A Stipulated Order for Permanent Injunction with the Federal Trade Commission (FTC).
These agreements contain various specific requirements concerning, for example, governance, policies, training, risk assessment, monitoring, disclosure programs, incentive compensation, data analytics, independent assessments, certifications, and further require scheduled and ad hoc reporting and notifications to the respective government agencies.
At their core, the agreements are geared toward the ongoing administration of an effective compliance program. Indivior committed to building an effective compliance program, and engaged in extensive program building, staffing and preparedness efforts, long before the 2020 Resolution Agreement.
The Group maintains this commitment today as the established ICP continues to evolve and mature based on internal learnings and relevant external benchmarks, as noted above. Indivior has established policies and procedures and government agreement administration protocols that have assured and continue to guide the successful implementation of the requirements of all three agreements, which is overseen by the Chief Integrity & Compliance Officer and the Compliance Committee (comprised of all members of Indivior’s Executive Committee). These policies, procedures, and protocols are well-integrated into ongoing business operations. To date, the Group believes that all requirements specified in the three agreements have been met, including the filing of all required scheduled and ad hoc reports and notifications.
Supplier Code of Conduct
During 2021, Indivior published its first Supplier Code of Conduct. This initiative followed on from the publication of the updated Global Code of Conduct in 2020.
