In many regions, we rely on Third Party Representatives to do business on our behalf. They play a vital role for us and in doing so must comply with applicable laws, industry codes and the Smith & Nephew Code of Conduct. We also rely on other service providers, such as suppliers, advisers and consultants. We take all reasonable steps to select service providers that are committed to compliance with the law and ethical behaviour.
We select Third Party Representatives based on their qualifications, reliability and adherence to applicable laws and our values. We take reasonable care in selecting them and do appropriate reviews from time to time. We require that they commit to adhere to the law and the Smith & Nephew Code of Conduct and that they have the training and tools to do so.
We never authorise or allow a Third Party Representative or other service provider to act improperly on our behalf. We are alert to indicators that service providers are behaving improperly, including those identified on our compliance website, and we bring them to the attention of our compliance professionals.
Rules for distributors and agents of Smith & Nephew relating to payments, disclosures, interactions with Government Officials and HCPs, gifts, travel, training and education, public tenders, fair competition, conflicts of interest and other matters are included in the Additional Compliance Standards (ACS) that were issued to you as part of your engagement with Smith & Nephew. Please refer to the ACS for guidance.
If you are a distributor or agent for Smith & Nephew, we have a set of tools that can help you build or strengthen your compliance programme.
Email us at GlobalCompliance.Communications@smith-nephew.com to request a copy of “Easy steps to manage compliance: A guide for distributors and agents.”