We have established a comprehensive corporate Ethics & Compliance program, overseen by our Chief Ethics & Compliance Officer under the direction of the Audit and Risk Committee of our Board of Directors. The Chief Compliance Officer has appropriate authority to exercise independent judgment and has free and unencumbered access to the Chief Executive Officer and the Chair of our Audit and Risk Committee.
David Alexander is our Chief Ethics & Compliance Officer, overseeing our global Ethics & Compliance Department. The Department has responsibility, among other things, for our Code of Conduct and other policies affecting our compliance with healthcare laws and regulations, compliance training and awareness, monitoring and risk assessments. Mr. Alexander is supported by a team of professionals with experience in healthcare compliance, data privacy, transparency and similar disciplines.
Mr. Alexander makes regular reports to the Compliance Management Committee, comprised of the Chief Executive Officer, Chief Financial Officer, Chief Legal Officer, and other executive leaders of Bausch Health. He also reports regularly to the Audit Committee of the Board of Directors. Both bodies routinely evaluate the Company’s healthcare compliance risks, ensure applicable policies and procedures are implemented to mitigate those risks, and monitor the Ethics & Compliance program’s effectiveness.