Code of conduct & compliance

Compliance, Ethics and Transparency

Being an ethical company is about much more than simply adhering to the letter of the law. But it’s an important step. MSD Ireland are fully committed to acting ethically in all that we do, in being transparent in all of our interactions and in partnering with Government and the HSE to ensure timely access for patients to new medicines and treatments.

Ethical behaviour is the duty of every employee in MSD Ireland, and as part of our long-standing commitment to ethics and good corporate citizenship, our first step is always to comply with the laws and regulations that govern the way we market and sell our medicines, vaccines and other products.

We have a well-established compliance program that:

• adheres to the code of practice and regulatory requirements of several regulatory associations including the Irish Pharmaceutical Healthcare Association (IPHA) and the European Federation of Pharmaceutical Industries (EFPIA) as well as the HPRA, the HSA and the Environmental Protection Agency.
• seeks to prevent, detect and resolve potential violations of law or company policy; and
• undergoes regular assessment and adjustment to make sure we are being responsive to our evolving business and associated compliance risks.

MSD Ireland fully participates in and supports the ‘IPHA Disclosure Code’, which details how the pharmaceutical industry in Ireland engages with and supports healthcare professionals (HCPs) and healthcare organisations (HCOs) to provide better patient care. This initiative is consistent with our approach in MSD to providing greater transparency around our company interactions with key stakeholders and we have been actively engaged in this process across all the European markets we operate in.

Our board of directors and senior management, including the company’s chief compliance officer and corporate compliance committee, oversee the company’s global compliance program, including compliance-related policies and procedures, education and training – all of which reflect the highest standards and are tailored to our business and culture.

In addition, we:

• require employees to report potential violations of law or company policy;
• hold ourselves accountable for responding promptly when potential violations arise; and
• examine whether identified violations are in part due to gaps in our policies, practices or internal controls and, if so, take appropriate action to prevent future violations.