Life Sciences Horizons Brochure 2025 - Flipbook - Page 92
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2025 Horizons Life Sciences and Health Care
How global antitrust compliance programs may help pharmaceutical companies
The increasingly stringent approach of the global
antitrust regulators in overseeing the pharmaceutical
industry is continuing to push companies towards
efficient tools to secure antitrust compliance and
mitigate antitrust risks. Although every jurisdiction is
unique from legal and regulatory perspectives, there
are general antitrust law restrictions and guidelines
that can be broadly applicable.
Therefore, identifying those regulations, and crafting a global
antitrust compliance training program – that addresses key “dos”
and “do nots” – remains a manageable, and beneficial, exercise.
Our key tips for a successful program are as follows:
Antitrust legal training should be customized for its audience,
for example, the global and regional leadership, and on
a national level, may be customized with local law and
enforcement practices. It is critical to raise awareness with
all business divisions; it does not make much sense to
train leadership but not train sales staff, because a sales
representative’s actions may create antitrust risks equally
as serious as the actions of company’s CEO.
The primary goal of the training should be to raise awareness
of the antitrust legal framework, practice, and risks of the
company’s business functions that do not deal with law
enforcement on a daily basis. The training must be organized
in the way such that the business teams feel comfortable to
open up and to raise questions and concerns they may have,
so that potential issues can be identified and duly addressed.
To bolster the program, a global antitrust compliance
training program may be used to introduce a global antitrust
compliance policy, or amendments to such policy, or may be
run in parallel with a company’s internal antitrust compliance
audit. A global compliance training program may also be
complemented by dawn raid training, to also increase
awareness regarding inspections.
Overall, a global antitrust compliance program may not only
assist a business in mitigating risks of fines, criminal sanctions,
exclusion from tenders, invalidity of contracts and damages –
including for reputation and brand – but also in strengthening
corporate compliance culture.
Natalia Gulyaeva
Partner
Dusseldorf
May Lyn Yuen
Partner
Brussels
Ilana Kattan
Counsel
Washington, D.C.
