Rudiments of an Effective Compliance Program
Pharma Tech Outlook

A featured contribution from Leadership Perspectives: a curated forum reserved for leaders nominated by our subscribers and vetted by our Pharma Tech Outlook APAC Advisory Board.

Zoetis Inc.

Rudiments of an Effective Compliance Program

Jeffery Williams

As the Chief Compliance Officer, what are some of your key roles and responsibilities that you take while serving at Zoetis Inc.?

As Chief Compliance Officer, my most important overall responsibility is to work with Zoetis leaders and colleagues at all levels across Zoetis to sustain our strong culture of compliance and make sure the compliance program equips and empowers colleagues with what they need to meet our high expectations for ethical business conduct.

The Zoetis culture of integrity is framed in one of our five Core Beliefs, “Always Do the Right Thing.” I have direct responsibility for our code of conduct, anti-bribery and anti-corruption program, conflict of interest program, compliance reporting helpline and internal investigations.  I also support several other related functions including data privacy and global trade compliance.  Additionally, I lead Zoetis’ Enterprise Risk Management program, which is critical for the long-term performance and sustainability of Zoetis.

What are some of the challenges existing for the leaders looking to establish key pharma compliance programs at their organizations?

Establishing meaningful connections with colleagues globally: It’s critical (but not always easy in a complex, highly regulated global enterprise) to find a way to connect with colleagues, both in-person and virtually, so that any aspect of the compliance program they utilize works as intended, is perceived as helpful and valuable -- and ultimately supports colleagues fulfilling our Core Belief “Always Do the Right Thing” in what they do for Zoetis every day.

Reducing process and system complexity:  It’s essential to understand how your business works in order to customize process and systems to address compliance risks effectively.  The best process and systems are the result of thoughtful interactions involving the colleagues who ultimately need to apply the policy and utilize the systems, starting at the design phase.  It’s important to recognize that even the best systems and process can always be improved in some way and need to constantly evolve with business operational changes.

“Adaptability, flexibility and resiliency are key attributes needed for the compliance program to meet these challenges”

Adjusting the compliance program based on evolving business models, initiatives and innovations: A key attribute of an effective compliance program is the ability of the program to innovate and evolve along with the business it guides and protects from compliance risks.  Adaptability, flexibility and resiliency are key attributes needed for the compliance program to meet these challenges.  Feedback, through formal and informal mechanisms, advice and support from internal experts and innovators is invaluable for the compliance program to remain relevant and meaningful as it must.

The industry is in the midst of a fundamental transformation, as the scale of operations is growing. The year 2022 is having pharma companies oriented to staying agile and resilient in regards to disruption bred by the fluctuating market demands and diverse customer needs. Your views on this?

The pace of change and disruption seems to accelerate continuously.  It puts a real premium on compliance programs to understand the challenges our colleagues deal with in the markets they serve and respond to them with in a way that enables exceptional business performance in compliance with the law and grounded by our Core Beliefs.  We need to be ready to respond to these changes as they occur, and to make sure we are doing our best to identify them over the horizon, through our Enterprise Risk Management Program, interactions with leaders and colleagues generally, and other feedback mechanisms integral to our program. 

With all this change it’s equally important not to lose sight of the fundamentals: making the program resonate with colleagues and their personal commitment to doing the right thing; making the complex simple to understand and do; and adapting to ever changing circumstances.

What would be your piece of advice for your fellow peers and leaders?

• Be humble. Take advantage of all the expertise in your organization to build and continuously improve your program.  Recognize that the best answers to compliance challenges often come from the colleagues who the compliance program is intended to support. You will find that there is a reservoir of good faith, and that your colleagues across the company are eager to help you get it right.

• Be grateful. Recognize the privilege you have to be part of a great company with a strong ethical business culture, and to work with great teams and colleagues across the globe.

• Have fun and enjoy what you do.  If you do not find the challenge fulfilling and enjoyable you should be doing something else.  Life’s too short.

The articles from these contributors are based on their personal expertise and viewpoints, and do not necessarily reflect the opinions of their employers or affiliated organizations.