As described in Counsel to Counsel Connections, Vol. 3, Summer 2003 at 12, Genentech, the biopharmaceutical firm, had at the time a web-based compliance program that offered or complemented six functions.
The program displayed the company’s Code of Ethics and also Good Operating Principles. It had “policies, procedures and controls for every commercial unit that are updated on a regular basis. Its third offering was interactive training programs, for which “All personnel must participate, be tested, and receive minimum scores” to remain employed. The system had an audit facility to track reports required and issued by commercial units. It also listed the disciplinary guidelines for actionable offenses and it fit with a hotline for employees to seek information and report issues (See my posts of Dec. 19, 2005 on BP’s similar resource; and July 5, 2006 on the genre of software as a cottage industry.).