The Program consists of the following components:

• Chief Compliance Officer and Corporate Compliance Committee

  The Boehringer Ingelheim Corporate Compliance and Ethics Program is under the direction of the Chief Compliance Officer, who is a member of the Corporate Compliance Committee. The Corporate Compliance Committee is comprised of senior executives of the Boehringer Ingelheim Corporation and its subsidiaries. The Chief Compliance Officer also provides annual updates, and substantive matter updates as required, directly to the Board of Directors of Boehringer Ingelheim Corporation.

• Corporate Policies and Procedures

  The company provides its employees guidance on certain legal issues as well as procedures for implementing business practices. This guidance can come in many forms. It may be in the form of corporate policies/procedures or individual subsidiary policies/procedures. It may also come from department-specific policies and procedures. Sometimes, it may come from more informal direction from management or other leaders in the company. The company continually evaluates and refines its policies and procedures to address specific and applicable legal, regulatory and business requirements. Policies and procedures are made available through employee manuals, department managers, and/or on the company’s web sites.

  Sales and Marketing Compliance is one specific area in which the company has expended an enormous amount of effort and compliance resources. Under the guidance of the Sales and Marketing Compliance department, Boehringer Ingelheim has developed specific policies and procedures to address issues identified in the OIG Guidance document and the PhRMA Code. These policies and procedures are provided to the relevant employees in a variety of formats. For example, our field based employees each receive a "Performance with Integrity Guide.” The Guide is a tool to assist field-based employees in meeting the high standards of Boehringer Ingelheim and provide them with a quick summary and description of the application of policy to key sales and marketing activities. Additionally, there is targeted training designed specifically for the field force on many of these same issues, policies and procedures.

  Areas addressed through policy development, procedural implementation and training programs specifically for Sales and Marketing include some of the following:

  • Code of Conduct
  • Product Promotion
  • Sample Management
  • Grants and CME Support
  • Promotional Speaker Programs
  • Charitable Donations
  • Local Exhibits & Displays
  • Patient Assistance Programs
  • Requests for Medical Discussions and Limitations on Interactions with Company Field-based Medical Personnel
  • Business Intelligence
  • Adverse Event Reporting
• Code of Conduct Annual Certification

  The Code of Conduct is the cornerstone of BI's culture and is designed to ensure that ethical compromises are never made and that all actions are honest and ethical.  The Code provides guidance for performing with integrity - in the workplace, in the markets where BI competes, in the local communities and with the public.

  All employees must carefully read and acquaint themselves with the Boehringer Ingelheim Code of Conduct. Under company policy, all employees are required to annually acknowledge and certify that they have read and understood the Code of Conduct. Failure to do so will subject the employee to disciplinary action.

• Confidentiality

  For our Corporate Compliance and Ethics Program to be effective, it is essential that employees feel confident and secure when raising concerns and issues. Therefore, it is critical for employees to know that every effort will be made to ensure the confidentiality of the compliance process. To help achieve this, the company provides anonymous reporting capabilities through the Compliance and Ethics Helpline.

• Compliance and Ethics Helpline

  The Corporate Compliance and Ethics Program maintains a company Helpline that is available to all employees to ask for guidance on the Code of Conduct, clarification of policies or procedures, report compliance concerns or provide information to Corporate Compliance and Ethics. The Helpline can be accessed by calling a toll free telephone number (860) 958-9704 or on-line and is available 24 hours a day, 7 days a week. The Helpline is administered by an independent contractor. The toll free number is answered by vendor representatives who are specially trained in interviewing callers and collecting pertinent information. Reports summarizing the calls are sent to BI Corporate Compliance and Ethics within one day. The on-line Helpline allows employees to create their own email report by answering topic related questions. These reports are automatically routed to BI Corporate Compliance and Ethics.

  Whichever method is chosen, employees have the option of providing their identification or making an anonymous report. We recognize that in some cases, employees may not feel comfortable identifying themselves when reporting a compliance concern. Whether made anonymously or not, the identity of the employee and the fact that a report has been made will be kept confidential to the extent possible while still allowing a thorough investigation to proceed.

• Compliance and Ethics Training and other Resources

  In addition to the Code of Conduct, employees may be required to take additional training designated by the Corporate Compliance and Ethics Program and senior management. This training may be through an ethics and compliance on-line training program, other on-line or computer-based training programs specific to a department or organization, training on policies and procedures necessary to carry out individual job duties, and training required by the Human Resources department. This list is not exhaustive, and an employee’s training requirements will likely vary over the course of employment. Any training assigned to employees is part of the company’s overall compliance efforts to provide them with the information and guidance needed to meet Boehringer Ingelheim’s ethical and business standards and its legal obligations.

  In some areas of the company, employees may have access to a library of on-line training courses. The subjects of the courses cover a variety of business and legal issues that support any required training. The Compliance and Ethics Web site also hosts various tools and resources about compliance and ethics related subjects.

• Audits and Investigations

  Every concern, question and allegation of wrongdoing reported to Corporate Compliance and Ethics - whether via the Helpline, the Compliance and Ethics Web site, or by directly contacting the Chief Compliance Officer, the Director and Deputy Compliance and Ethics Officer, a member of the Legal department or reported through management - shall be reviewed, evaluated and responded to promptly and professionally, in a manner that respects the rights of all parties concerned. Follow up will include remediation and corrective actions as necessary, as well as appropriate disciplinary action when warranted. Investigations shall, to the maximum extent possible, be conducted confidentially. All employees are expected to fully cooperate with any compliance investigation.

• Corrective Action and Discipline

  Any violations of the Code of Conduct or company policies and procedures will be taken very seriously. When a violation is identified, prompt, thorough and appropriate corrective action will be taken in response to the violation. The response may include making changes to policies, procedures and/or other compliance processes to ensure that repeat or similar violations do not occur. Failure to comply with the Code of Conduct or any company policy or procedure will subject the employee to disciplinary action, up to and including termination of employment.

• Employee Responsibility to Report and Protection from Retaliation

  In addition to acting in compliance with the Code of Conduct and our policies and procedures, every employee has the responsibility to report to the company any violations of the Code of Conduct, law, policy or procedure that he or she may discover. Employees are assured that they can report such violations without fear of retribution or retaliation. Any employee who threatens, retaliates against or harasses any person who has reported in good faith a compliance concern, or is considering reporting such a concern, shall be subject to disciplinary action, up to and including termination. Employees are encouraged to report such violations directly to management. They are also counseled to talk to someone in the Human Resources department, the Legal Department or Corporate Compliance and Ethics. However, if employees believe concerns cannot be raised in either of these manners, they are strongly advised to use the Compliance and Ethics Helpline, where reports can be made anonymously.

• Federal and State Laws

  Vermont Pricing Disclosures

  Under Vermont law, pharmaceutical marketers are required to disclose the prices of the drugs they market to Vermont doctors and other persons authorized to prescribe drugs in Vermont. When disclosing the prices of the drugs they market, the pharmaceutical marketers must also disclose the prices of others drugs in the same therapeutic class.

  Below, you will find links to the disclosure forms for each of the pharmaceutical products that Boehringer Ingelheim Pharmaceuticals Inc. markets and for which such disclosure is required. The disclosures are provided in the format required by the Vermont law and subsequent guidance documents.

  The Average Wholesale Price ("AWP") listed for Boehringer Ingelheim Pharmaceuticals, Inc. (“BIPI”) Marketed Products is derived by the third party publisher. BIPI does not set or provide an AWP price to or for any third party publisher, nor does BIPI assign an AWP to any of its products.

  Prescription Medicines:

  • Aggrenox®
  • Catapres®
  • Flomax®
  • Micardis®
  • Mirapex®
  • Mobic®
  • Persantine®
  • Viramune®

  California State Requirements

  To read our annual public declaration of compliance with our Corporate Compliance Program,
  click here.

  California has implemented a law requiring that companies establish a specific annual dollar limit on gifts, promotional materials, or items or activities that they may provide to healthcare professionals. We have set an annual dollar limit of two thousand five hundred dollars per healthcare professional. Please note that this amount represents the maximum limit, and does not represent the actual average annual amount per healthcare professional. Drug samples given to healthcare professionals intended for free distribution to patients and financial support for continuing education and health education scholarships are exempt from this limit, as are payments to healthcare professionals for legitimate professional services.

  Transparency and Disclosure

  On January 1, 2012, the U.S. Food and Drug Administration (FDA) and Centers for Medicare and Medicaid Services (CMS) will put into effect the Physician Payment Sunshine Act. The Sunshine Act is part of the Patient Protection and Affordable Care Act, and is a government statute that requires all pharmaceutical companies to report any payment or transfer of value to healthcare providers (HCPs) or healthcare organizations (HCOs).

  Transparency about our interactions with healthcare providers and healthcare
  organizations is important to the ethical conduct of our business. BI supports the
  principle of transparency and wants stakeholders, including patients, industry
  groups and state and federal authorities, to understand the importance of our
  engagements with healthcare providers and healthcare organizations in support of our business.