Upright’s mission is to maximize the impact of Ethics & Compliance Teams worldwide. Working together with the inspiring Ethics & Compliance team at a company, our common goal was to help maximize impact across more than 30 countries around the world while increasing efficiencies along the way.

The output: more automation, more transparency and faster reporting.

Since adopting Ethical: Program Management and Ethical: Matters Management across the group, significant improvements with respect to monitoring global program progress were achieved while cutting the time it takes to report on results by a factor of three.

The Compliance Director at our Customer explains:

“Ethical is the one stop shop to support effective and transparent communication throughout our organization. It enables clear task setting for our business units, and it is a fantastic tool to transparently show where we stand with our compliance program and how we progress over time.”  

The Context our Customer Operates in

Headquartered in Europe, our Customer's organization spans across more than 30 countries, delivering treatments to patients in over 70 countries worldwide. Operating in a highly regulated environment, our Customer's Ethics & Compliance team has lots on its plate to enable the company to navigate the risk landscape proactively while enabling business to making informed decisions.

The Ethics & Compliance Team there covers topics ranging from anti-bribery and- corruption to data protection and more. Key initiatives are defined centrally, and operationalized on regional levels.

The Compliance Director at this Customer, shared with us her experience implementing Ethical Program Management and Ethical Matters Management to manage and effectively implement the Company's E&C strategy the numerous markets that she oversees, with their varying sizes, regulatory specifications and complexities.

The challenges of effectively implementing a program on the ground in vastly different countries

Our customer operates in highly regulated environments, and that elevated complexity strongly impacts the work the Ethics & Compliance Team at our Customer manages every day.

Working with full time and part-time compliance employees responsible for a market or a cluster- of markets, the  Global team needs to ensure key initiatives defined at the global level are effectively implemented, operationalized and adapted in accordance to local specificities and regulations.

At affiliate  level, all Topics land in the hands of specific appointees, some of whom may originate from Compliance but others main responsibility are in Quality, Transparency or Finance and have Compliance as an added task without having previous experience in this area.

Therefore, it was critical to find a tool that would make it easy for all compliance colleagues to receive, understand and embed all necessary E&C initiatives on the ground.

The main pain points faced by the Ethics & Compliance team were:

• Outreach: Reaching out to the colleagues in more than 30 countries to ask them to deploy initiatives or report information: this was done via emails and newsletters, which required various follow-ups and reminders;
• Tracking: keeping track of all deployed initiatives and where everyone stood in each of the 30+ countries with more than 15 Excel spreadsheets and very little time to do so;
• Quality of the information collected: a lot of work was dedicated to make sure team members would effectively respond to the questions asked, and the E&C Team had to regularly and individually follow up, ask for more information or request different information than the one provided;
• Time management: lots of time was spent on compiling information received and creating summaries to report on: for her regular monitoring, the Compliance Director often spent more than three business days aggregating all the findings collected, combining them and making sense of the results to effectively draw conclusions.

In short, there was room for automation and our Customer's team was eager to take advantage of it.

Why our Customer chose Upright Solutions & how Upright supports today

One of the things our Customer's E&C team valued when seeing Upright’s E&C Governance & Reporting tool was the fact that the solution was developed hand in hand with companies of different backgrounds and a variety of our customers’ in-house Ethics & Compliance teams.

According to our Customer’s Compliance Director :

“Working together with the Upright Team feels like a partnership where it is possible to share ideas and make our vision come true with the out of the box functionalities that they offer. Everything can be easily configured to fit our exact needs. The tool is also easy to set-up and very intuitive to use. Lastly, the Upright team is really fun to work with: there is not one problem that we cannot solve together to reach the next level of maturity we want to achieve at our Company. I feel that we can grow and take our Compliance program to the next maturity level by using Ethical.”

With everything being self-service in Ethical, our Customer's E&C team remains fully empowered to run their initiatives at their discretion and to adjust their set-up to the changing nature and needs of its ever evolving organization whenever necessary.

The Result of the deployment of Ethical

Our Customer uses Ethical: Program Management as a one stop shop to deploy their Ethics & Compliance strategy, including to:

• Deploy their policies and procedures, such as Healthcare Compliance Policy and SOP, dawn raid procedures, and to ensure they are communicated, adjusted and updated in all markets;  
• Ensure the network of E&C Correspondent is equipped for success: the E&C Team runs regular surveys to get a pulse from the correspondents thereby ensuring they are empowered to roll out their E&C initiatives successfully. The correspondents’ feedback in turn informs the overall Compliance strategy and thus drives the deployment of activities in Ethical;
• Collect all sorts of data on policy deviations from the markets to inform upcoming audit or monitoring plans, from lists of local third parties to sampling transactions;
• Run an effective monitoring: it’s a matter of minutes to create a Questionnaire that can be used for sample testing in all markets, ensuring that existing processes are followed everywhere at all times. For example, just a few days ago, the team launched their latest monitoring project on sponsorships in the form of a Questionnaire where local market practices are checked against existing policies on a basis of 10+ randomly selected samples per affiliate;
• Manage the legal aspects of compliance: store and collect local contract templates, ensure the local contacts are updated as per the latest regulations and so on.

Our Customer also uses Ethical: Matters Management to enable local correspondents to communicate information proactively, including notably:

• Exception requests to policies and procedures;
• Process adjustments and deviations at all levels of the organization;
• Deviations identified from the monitoring including their corrective action plans, with full documentation and a full audit trail.

According to our Customer's Compliance Director, Ethical by Upright “is the ideal platform to keep track of the compliance teams, all initiatives and at the same time generating data that can be used to support risk management."

Thanks to their successful implementation of Ethical, our Customer now benefits from:

• Transparency at all levels: for the 30+ markets, this means clarity on what every team needs to do and where they stand. For the Chief Compliance Officer and the Global Ethics & Compliance Team, this means transparency upwards and clarity on the progress made. Whatever they need, whenever they need it: all data is neatly organized, updated in real-time, and readily available to report on.
• A dashboard per market: the Compliance Director uses these dashboards as a basis to hold her monthly catch-ups with the affiliate Compliance members in each market, enabling data driven exchange and effective communication on progress made. All deviations are tracked and documented and the engagement with the Network is facilitated.
• Next level monitoring: the Company was able to launch and enhance its monitoring program involving sample testing in each business unit, so that findings of deviations can be tracked and remediated swiftly, with the goal to repeat the monitoring regularly and measure progress and effectiveness over time.
• No data loss or slowing down in case of change of personnel: all tasks, questionnaires and matters are linked to the business units in Ethical: no matter whether people change or move, the work and progress made stays available for new-joiners, who can pick up things that have been left by their predecessors!  

What’s next for our Customer's E&C Team

The adoption of the solution by the network is great. For the future, our Customer's vision is to progressively increase the deployment of their comprehensive control framework using Ethical. Moreover, the team is already investigating options to move their continuous Risk Assessment efforts into the platform, which comes in handy given that Upright’s latest product Ethical: Risk Assessments went live just a few months ago.