Topics Held the "FY2021 Meeting of Compliance Managers and Practitioners
On March 1, 2022, the Pharmaceutical Manufacturers Association of Japan (PMAJ) Code Compliance Promotion Committee held the "FY2021 Meeting of Compliance Managers and Practicing Managers" in the same online format as in FY2020. The meeting was attended by 132 compliance managers and compliance practitioners from 73 member companies and was conducted according to the program shown in Table 1. A summary of the meeting is reported below.
Table 1 Program of the "FY2021 Meeting for Compliance Managers and Practitioners"
(1) Opening remarks
Prior to the meeting, Satoshi Tanaka, Chairperson of the Pharmaceutical Association of Japan Code Compliance Promotion Committee, explained the basic policy and key issues of the Committee for FY2021: "Support for member companies' compliance promotion," "Promotion of appropriate information disclosure based on transparency guidelines," "Response to guidelines on sales information provision activities for ethical drugs," and "Support for administrative and regulatory compliance. The Committee also outlined its basic policies and priority issues for the year 2021: "Supporting member companies in promoting compliance," "Promoting appropriate information disclosure based on transparency guidelines," "Responding to guidelines for the provision of information on the marketing of prescription drugs," and "Collaborating with the government, JFMA, JFTC, IFPMA, and other related domestic and foreign organizations, collecting and disseminating information and providing feedback.
He also reported that the revision of the Transparency Guidelines was approved in January 2022, and that member companies shared their efforts for the Guidelines for Marketing Information Provision Activities, and stated that they will collect and disseminate information on global trends in the International Federation of Pharmaceutical Manufacturers and Associations (IFPMA) and Asia-Pacific Economic Cooperation (APEC). Chugai will continue to collect and disseminate information on global trends in IFPMA and APEC.
Pharmaceutical Association of Japan
Code Compliance Promotion Committee
Satoshi Tanaka, Chair
(2) Introduction of compliance initiatives of member companies
Hitoshi Aikawa of Chugai's Sustainability Promotion Department gave a presentation titled "Status of Efforts Concerning the Whistleblower System.
He then introduced the "Chugai Group Code of Conduct (CCC)" and related guidelines and regulations as part of Chugai's efforts to develop guidelines and regulations related to whistleblowing. He then introduced the "Chugai Group Code of Conduct (CCC)" and related guidelines and regulations.
He introduced that Chugai has established multiple contact points for reporting and consultation, and has a system for easy consultation whereby the person consulting can choose which contact point to use. In addition, he stated that employees in charge of these consultation services are making efforts to acquire knowledge and skills by attending internal and external training sessions so that they can respond appropriately.
In addition, he stated that the company strives to create an environment that facilitates reporting and consultation, and as part of its educational activities to enable timely and appropriate reporting and consultation, the company uses posters and introduces the person in charge with a photograph. In addition, he introduced that a compliance awareness survey is conducted every year, and that a Q&A is prepared to eliminate concerns and questions of consultants identified in the survey, and that past consultation cases are posted on the website. He reported that these activities have been successful, with some consultants commenting that they consulted with the company after seeing the posters or because similar cases were introduced.
Sustainability Promotion Department, Chugai Pharmaceutical Co.
Mr. Hitoshi Aikawa
Finally, he introduced key points regarding the revised Whistleblower Protection Act, which will be enforced in June 2022, and concluded by saying that it is important to provide an environment in which employees feel comfortable discussing any questions they may have, and to repeatedly respond appropriately to these questions.
(3) Special lecture
Ms. Ikuko Yamane, Chief Researcher, Organizational Behavior Division, Japan Management Association Research Institute, gave a lecture titled "Compliance Survey with Specific Figures.
Ms. Yamane stated that the purpose of her presentation was to reconfirm the significance and purpose of quantifying employee awareness by conducting a compliance survey, and to discuss with everyone how to utilize the survey results. He also emphasized that it is important not to be happy or sad about the results of the compliance survey, but to analyze the reasons why the score is high (or low), and to "put it into practice" by developing measures and improving the workplace culture based on the survey results.
In the prerequisite section, we stated that the definition of compliance is not only legal compliance, but also behavior that takes into account legal, internal, and social norms, and that the purpose of compliance is to improve corporate value and business continuity as a voluntary activity, and to gain the trust of stakeholders.
He further discussed the "whistle-blowing system" and "checklist" as similar to the compliance survey and explained the difference in significance and purpose.
Chief Researcher, Organizational Behavior Division, Japan Management Association Research Institute
Chief Researcher, Organizational Behavior Division
Ikuko Yamane
In this part, he explained how to proceed with the compliance survey as an eight-step process: (1) organizing the purpose of the survey and awareness of issues, (2) creating a framework and items, (3) actual survey, (4) tabulation, (5) analysis, (6) reporting, (7) thanking and disseminating the survey, and (8) implementing an action plan.
In "(2) Framework and Item Creation," if compliance awareness can be leveled through the compliance survey, goals and issues can be identified. Since employees' decision-making criteria are greatly influenced by the company's organizational climate and their supervisors, it is desirable to include items related to organizational climate, supervisors, and workplaces in the survey items.
In (5) "Analysis," each participant answered the actual questions and compared their answers to the average of other companies to follow the results and the process of consideration.
In (6) Reporting, he introduced his know-how as a survey practitioner, including response trends by attribute, response trends in the Corona Disaster, and examples of responses to open-ended questions.
In the section "(8) Practicing Action Plans," he stated that the survey results should be used to identify positive aspects and issues in the company and each department, which should then be incorporated into action plans for the following year and put into practice, as well as used for selecting training themes.
Lastly, he also recommended that the survey results be fed back not only to management and department heads, but also to employees. As a point to keep in mind when providing feedback in the workplace, the main purpose of the compliance survey is to reflect the results in workplace activation and activity measures, and the data should not only show the "psychological facts" but also the background of the score, for example, what the members feel is the problem. He also requested that the data be used in such a way that it can be shared and used as a vector for activities to improve workplace management. He also requested that the data be used in a system that enables responses with peace of mind, such as by taking sufficient care not to identify individual respondents.
(4) Closing remarks
Mr. Tokuo Tanaka, Executive Director of the Pharmaceutical Manufacturers Association of Japan (PMAJ), thanked the speakers, Mr. Aikawa and Mr. Yamane, and expressed his appreciation for the participation of compliance managers and compliance practitioners in this meeting and their daily activities.
He emphasized that the pharmaceutical industry, which handles life-related products, has been working on thorough compliance since earlier than other industries, and that the occurrence of noncompliance by a single company could cause a major loss of public trust in the pharmaceutical industry as a whole. Referring to the recent cases of GMP violations that have even affected the stable supply of pharmaceuticals, he said that it is too late to "thoroughly inspect the industry at that time," and that it will take more than twice as much time to regain the lost trust as it has taken to build it up.
Unfortunately, the number of compliance violations has not yet reached zero. He explained that the major cause of the problems that develop from whistleblowing, etc., as mentioned in today's lecture, is poor initial response, and that it is important for the company to take it seriously, take appropriate action, and convey the message to the whistleblower and to the entire company that the company has changed. The training was enthusiastically conducted by each company, and although the participants had the knowledge, would they be able to respond appropriately in an actual situation? He emphasized that ethical standards can be said to have been demonstrated only when accompanied by actions.
Mr. Tokuo Tanaka, Executive Director of the Pharmaceutical Manufacturers Association of Japan (PMAJ)
In closing, he asked the MRs to "protect MRs through the Compliance Department. I want you to make the company healthy. That responsibility lies with all of you! He concluded with the following words: "I want you to protect MRs through the Compliance Department and make the company healthy.
( Takashi Tamada, Practice Committee Member, Code Compliance Promotion Committee)
