Business Ethics and Compliance

The Pharmaceutical Research and Manufacturers of America (“PhRMA”) “Code on Interactions with Health Care Professionals” (“PhRMA Code”) is a voluntary framework for pharmaceutical companies which addresses interactions with health care professionals that relate to the marketing of pharmaceutical products.  While voluntary, some states and jurisdictions require pharmaceutical companies to adopt a compliance program and policies consistent with the PhRMA Code and make an annual written declaration of compliance with the PhRMA Code.

Cordavis embraces the underlying principle of the PhRMA Code—namely that “a health care professional’s care of patients should be based, and should be perceived as being based, solely on each patient’s medical needs and the health care professional’s medical knowledge and experience”.  Cordavis’ business model, all activities in support of its business model and its Compliance Program are consistent with that principle.  Moreover, the Compliance Program is designed to foster compliance with the federal Antikickback Statute which also ensures ethical interactions between pharmaceutical companies and healthcare professionals while avoiding kickbacks and inducements.  

To the best of its knowledge and based on a good faith understanding of the regulatory landscape, statutory requirements and the PhRMA Code, Cordavis is not currently engaged in any of the activities outlined in the PhRMA code.  Specifically, Cordavis does not employ sales representatives, engage in transfers of value to health care professionals or conduct any form of marketing to health care professionals.  Accordingly, Cordavis’ Compliance Officer will not complete an annual PhRMA Code certification at this time.  Cordavis will reevaluate the need for certification and adoption of policies more specifically aligned to the PhRMA Code if its business model evolves to include PhRMA code governed interactions with healthcare professionals.