Jonathan Turner, Vice President, Compliance, Smith & Nephew, Memphis, TN
GZ: Thanks for taking the time to be interviewed for Compliance Today. Our readers may recognize Smith & Nephew as a medical device manufacturer, but can you tell us a bit about its operations, geographic reach, etc.?
JT: Smith & Nephew was founded in 1856 and has grown over the past 162 years to more than 15,000 employees today. Traded on the London Stock Exchange, Smith & Nephew is a multinational medical equipment manufacturing company headquartered in London. The company is a leader in advanced wound management, orthopedic reconstruction, trauma, and sports medicine that help patients in over 100 countries around the globe. Our products range from external and implantable medical devices to pharmaceuticals, which makes Smith & Nephew a dynamic and innovative organization.
GZ: Healthcare-related organizations are subject to regulation in the US, UK, and other parts of the world. Can you give a brief overview of the regulatory framework you operate under and some of the key risk areas?
JT: We face many of the same commercial risks that other organizations face, but with an added level of scrutiny. Inside the United States, medical device and pharmaceutical companies operate under the very broad breadth of the Anti-Kickback Statute, which requires companies to closely monitor their interactions with healthcare providers, both individuals and entities. Outside of the United States, many healthcare providers and organizations are part of government entities, which brings anti-corruption laws into play, such as the US Foreign Corrupt Practices Act, the UK Bribery Act, and the long list of local anti-bribery laws. This means that companies like ours have to implement processes and controls and carefully document our interactions with healthcare professionals to ensure we can demonstrate the legitimate intent of these activities.
GZ: For a global organization, staying on top of compliance-related developments and changing risks can be very difficult. How do you stay current on the many compliance developments that affect your company?
JT: This is where working with a great team makes a huge difference. We are fortunate to have a diverse team of talented professionals located all over the world who bring local expertise and knowledge together within a global framework. We extend that knowledge through active membership in trade associations like AdvaMed and MedTech Europe, as well as regular updates from law firms and other consultants. We then communicate throughout the company to ensure that all of the relevant stakeholders are informed of developments.