Post By: Adam Turteltaub

Brooke Nelson (LinkedIn), Executive Director, Worldwide Compliance and Business Ethics at Amgen had a unique and broad perspective on managing compliance during the pandemic.

In this podcast she shares what she has seen, including a drop in incidents in many areas.  Part of that, she believes, is likely due to the fact that people were disconnected.  With sales reps less able to make calls on medical practices there were less interactions and less opportunities for things to go awry.

When it comes to investigations the adjustment to the pandemic has gone better than might be expected.  As she notes, global organizations have always had to rely on some remote methods in the past when conducting investigations since you didn’t necessarily have compliance staff in every location.  During this era, though effective investigation practices in distant locations have likely grown more effective.

However, there remains a strong case for conducting at least some aspects of the investigation in person.  An in-person meeting can give a clearer read of the individual.  In addition, the presence of an investigation team may lead other individuals on site to share information that they might not have.  An investigations team physically present also offers another benefit:  it demonstrates the company takes investigations seriously.

With the US and other regions hopefully soon reopening, she does warn that compliance teams should be prepared, if they aren’t already, for change.  It is time, for example, to reiterate the need for the workforce to reach out and report their concerns through the helpline and other channels.

Compliance should also look out across the organization to better understand what is happening on a country-by-country basis, both for the business units and for the compliance team, itself.  There are likely significant disparities and a need to adjust efforts and expectations accordingly.

And, of course, the way we all work has changed, perhaps permanently.

Listen in to learn more about our recent past and what to consider moving forward.