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FOCUS 35


Organisations have to get smarter at detecting non-compliance, embracing forensic insight and data analytics


A pragmatic approach to compliance


As pharmaceutical and life sciences companies work to increase transparency and build trust, their prime objective has been to embed conventional risk management and governance frameworks.


While processes and procedures are undeniably important, they need to be accompanied by wider cultural change driven clearly and unambiguously from the very top. A mechanism for driving the alignment between corporate culture and the risk profi le is to provide employees with performance incentives that will motivate them to consider


risk and opportunity in every business decision they make. The balance between establishing an effective risk culture without stifl ing innovation is tricky but can be achieved.


A risk resilient culture nonwithstanding, even the most diligent businesses need to acknowledge the continued capacity for individuals to ‘do the wrong thing,’ whether it is due to personal greed, corporate ambition or pressure from peers and managers. Organisations therefore also have to get smarter at detecting non-compliance, embracing a combination of forensic insight and data analytics to help raise the ‘red fl ags’ that indicate inappropriate behaviour.


© 2014 KPMG LLP, a UK limited liability partnership, and a member fi rm of the KPMG network of independent member fi rms affi liated with KPMG International Cooperative, a Swiss entity. All rights reserved.


An experienced ‘corporate detective’ can get under the surface of apparently sound practices and unearth wrong-doing. A review of sales and marketing expenditure may reveal that a so-called client event actually happened at an impossible hour, indicating fraudulent use of corporate funds for another purpose.


Investigations of historic incidents have shown that many early warnings are often overlooked. A combination of compliance checks and balances, internal audit and external forensic experts can provide the scrutiny and the investigative skills to reduce the chance of unacceptable practices.


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