I would also like to thank the employees of company A for giving me a valuable experience to let me think about the topic of this paper. This study aims to analyze the compliance implementation of Company A, a global pharmaceutical company that provides biologics and pharmaceutical products in many parts of the world, including Thailand. And as such, Company A's compliance needs to be reviewed and revised to cover the former Company B's rules and regulations as the business and marketing strategy of the animal health and veterinary science products are different from those of Company A. .
Until today, the internal compliance enforced in this global company has been based on the original compliance of company A without any SOPs from the former company B. Given that what is considered to be the right practice , is that all questions from the 3rd business units must comply with each regional country's legislation and the company's compliance. However, some issues can be subjective and need to be considered and scrutinized in detail for the company's reputation.
LITERATURE REVIEW
Thus, ethical standards must be applied to companies, in addition to the implementation of company compliance. It should be taken into account that there are also differences in home and host country standards, which can impact the implementation of global compliance. This implementation does not imply the accuracy or truth value of the host country, as some of the practice may be permissible (Donaldson, 2004).
Global compliance of an international company conducting its operations from its home country must be aware of the differences in ethical values, culture, laws and regulations between the two countries. The Compliance Officer (CO) therefore works as an advisor to all employees and monitors the organization's compliance implementation projects under his supervision. The CO is placed at management level and to ensure that every employee acknowledges the company's compliance; The CO should work closely with the HR team on compliance training projects and disseminate all details to promote better understanding among staff members.
Foorthuis (2012) recommends that the Typology of Compliance Tactics is an effective way to review company compliance. The last level or individual level is the level for those who may directly be expected to comply (eg in the case of information security procedure) or who may be part of the collective required to comply (eg in the case of project that implements a medical administration system that must comply with privacy regulations). From the literature review, the following research proposition is derived: when two or more companies are about to merge, compliance implementation is likely to be influenced by the type of industry and the local culture of the host country where the company operates.
Reagan (1996) suggested that an international company that needs to conform globally when conducting its operations from its home country should be aware of the differences in ethical value, culture, laws and regulations between the two countries, especially the local country. The research applied the three organizational levels - the corporate level, the collective level and the individual level - and four focus on the organization on four topics: incentive, enforcement, assessment and management to analyze corporate compliance during the merger period.
COMPANY BACKGROUND
The Country Compliance Officer
The Country Compliance Officer or CO assumes all responsibilities in enforcing company compliance. The responsibility of the Country compliance officer is to observe ethical business conduct of the employees and promote business integrity in the company. If there are issues that could lead to non-compliance behavior, the CO will offer alternatives or options, or ignore them.
The CO participates in the training process of new employees and another major responsibility is investigating cases of non-compliance in the company. A case of non-compliance, if any, will be reported directly to the Global Executive Director. In addition, the CO must keep up with Thai law and regulations, and Thai culture in accordance with the company's compliance.
The CO supervises the 3 business units of company A: pharmaceutical products A-1, biological products A-2 and animal health products A-3. During the merger period, Company A appointed a committee to write the SOP with a detailed overview of all marketing projects of Company A-3's business unit, because launching a veterinary drug marketing project is different from the pharmaceutical projects that Company A has carried out . been practicing for several years.
The Writing Compliance Committee Members (SOP Committee) The committee members have been assigned to draft the company SOP aiming
The Nature of Animal Health Product Business
The most important thing is that each animal must be vaccinated at the same time, on the same day, to ensure the titer level of the herd. Within the agricultural animal health sector, it is thus necessary to deliver products to the farm in sufficient quantity and at a precisely specified time. In one household there are 20,000 broilers and each broiler must be vaccinated on the same day as specified in the program to increase the crop vaccine titer and to prevent the disease in the household.
The procedure to accomplish this task needs to understand the nature of the detailed animal health care procedure, the relationship between the sales representatives and the farm veterinarian with their team members including the farm workers who have to do the vaccination, the contracts of details and services that must comply with the business process. And the product is used for the individual and not for the whole community at the same time.
RESEARCH METHODOLOGY
Theoretical Framework
The Sampling Selection
- The Enterprise Level
- The Collective Level
- The Individual Level
The first selected sample is an employee who has worked for 3 years with primary responsibility for purchasing. The second sample is an accountant who is responsible for the company's financial reports. The third selected sample is a salesperson who has only been employed by the company for one year and must follow compliance strictly.
After the targeted selection of respondents, the interviews were scheduled for detailed information on the attitude towards compliance, its implementation, the obstacles and its impact on work procedures. Each sample was interviewed separately by the same interviewer to prevent any preference or any bias towards the given information or comments of the interviewer.
ANALYSIS AND FINDINGS
- SOP for Animal Health Products
- Compliance Committee Work Load
- Misjudgment by employees
- Trade-off between compliance and profit
- Trade-off between compliance and local business tradition
Company A's global compliance, as it existed before the merger, is considered effective because each country can design its own standard operating procedure (SOP) to suit each regional environment. This means that the company must follow the law or legal procedures and the ethical norms and culture of that country before writing the company's compliance. Company A found that its company's main problem after the merger was a lack of consistency across the company's 3 business units.
Currently, compliance only covers 2 business units, but the Company's Compliance review is not possible without the SOP, which will be the compliance guide covering animal health products. They all understand that they must comply with Company Compliance, which may not apply to their marketing projects. Committee members feel that writing the SOP becomes a burden on their day-to-day responsibilities, so they need compensation or the company should get an outside source to perform this task under the committee members' supervision.
Two respondents were so concerned about the project in the gray area because they did not want to violate compliance or any regulations, but since the SOP at the former company allowed some activities that were considered gray at Company A, they were not comfortable not feeling In pharmaceutical business, there are so many generic products introduced in the market, so the service and technical support of the company should be compared. Another example of a gray area is the Thai tradition of gifts to make customers feel positive about the company.
For the CO, stationery as a gift looks very professional and knowledgeable, especially pens which can be seen as a reliable gift for the company image. In fact, the company's brand image, corporate reputation and product values are built through marketing activities.
CONCLUSIONS AND SUGGESTIONS
- The Merging Period and Its Problems
- Formal Seminars at Various Levels
- Formal Seminar to get to know the A-3 business unit
- The Deadline for the Launch of the A-3 SOP
- Formal Seminar on the Company Compliance
- Formal Seminar for the Collective Level
- Training Approaches
- Interaction or Two-way Communication within the Company Another problem from the study is a lack of interaction and communication
Company A's SOP related to the animal health product has not been completed; as a result, there can be a gray area for employees to respect, so the CO was an absolute decision. It is suggested that all managers of units and departments and ZK attend this workshop. This assistant can reduce the workload of the CO and the Committee and can consolidate the cross-functional tasks that need to be fulfilled.
Once the new SOP is ready for implementation, there should be a formal seminar that everyone including the CO can attend. At the same time, each option can also be analyzed so that those employees who may become involved will have a clear understanding of the compliance and also the CO in particular. The CO must understand all the details of the business functions with specific intentions to do so so that the CO will understand the detailed business processes.
At the seminar sessions, the CO and participants can discuss in detail about project creation, criteria and feasible ways to reach and achieve the business objective. The CO should be considered a quasi-member of the company so that employees in doubt about compliance can get direct feedback and comments with good explanations rather than "non-compliance" and options. So there should be a session where the CO or any supervisors participate in the seminar with the employees trying to comply to clarify the unclear issues.
By doing this, the seminar will lead employees to gain a real understanding of both compliance and CO assessment and meet the SOP for more effective projects, a more efficient work process and the company's reputation. This is due to the lack of insight that the responsibility of the CO as an advisor to the Company with regard to compliance is questioned if necessary.
