GLG Compliance Framework

The value of tapping specialized expertise should be tempered by an awareness of its limitations. We at Gerson Lehrman Group, Inc., have worked with thousands of clients, companies and experts to develop a robust compliance framework. Compliance is a core commitment for our business, and we have invested heavily in proprietary systems and technology. Our systems and compliance protocols help experts manage conflicts and enable our clients to implement their own protocols.

COMPLIANCE PHILOSOPHY

Our compliance framework and tools are designed to supplement and enhance the compliance protocols of our clients and help them reduce their exposure to conflicts.
To enable this, we have built the industry leading systems to help identify and manage conflicts and to implement your firm’s compliance procedures. We have also leveraged our experience as an industry pioneer to develop expert training and important rules for expert engagements.

COMPLIANCE SYSTEM FOR EXPERTS

Contracts & Expert Training

Experts sign the GLG Terms and Conditions contract at joining and every year, requiring them to never disclose confidential information to clients and to maintain client information as confidential
Mandatory compliance training at joining and once per year ¹
GLG’s Contract Management System^SM tracks contract and compliance status

Limitations on Employed Experts

Experts are not permitted to participate in projects about their employer
GLG must receive employer consent for enrollment in GLG Member Programs^SM (the tier of experts eligible for in-depth and ongoing consulting projects)²

Conflict Management

Collection and storage of conflicts in GLG’s Knowledge Base^SM
Experts required to opt-in to all projects arranged by GLG Research Managers

The Institutional Registry^SM

The Institutional Registry effort is designed to foster transparency to employers and other information stakeholders
Outreach to thousands of public companies and automatic implementation of any prohibitions on outside consulting by employees of such company or any of its subsidiaries
Outreach through relevant trade groups and associations
Our Web site includes tools for companies to register their consulting policies

PROJECT OVERSIGHT TOOLS FOR CLIENTS

Suite of online compliance tools available to client administrators at no additional cost allows clients to:

Monitor research activity on a real time or historical basis
Limit project eligibility (e.g., automatically exclude public company employees)

Require pre-approval for (some or certain categories of) projects
Add client-specific content to GLG communications to users and Council Members
Embed compliance screening questions directly into the project invitation workflow

The Council Member training module is available in 16 languages/dialects.
Certain C-level executives (President, CEO, CFO,GC, COO) and partners in professional services firms are deemed able to self-consent.

CLIENT SERVICING RULES

Through its experience arranging hundreds of thousands of projects, we have developed additional rules of engagement. The following are some of these rules that govern client use of the GLG Inc. platforms:

Auditors and Finance Professionals

May not discuss financial or accounting issues relating to companies for which they have worked within the last six months or which they have audited within the last 3 years.

Channel Checks

Employees of companies (generally retailers and distributors) that sell other companies’ products and services may discuss products and sales trends, but not their own company’s specific numbers (e.g., sales figures).

Competitive Intelligence Limitation

Our services may not be used to obtain information from employees of competitors (of the GLG Inc. client or any intended recipient of such information).

Franchisees

May discuss their own franchises, but not their franchisors’ strategic plans, new product development, or specific performance data.

Government Officials

Our services may not be used to influence government officials (including any member of party, or candidate, whether in the US or elsewhere) in their official capacities, to induce public officials to breach their official duties, or to secure an improper advantage. Similarly, a government official may not on a paid basis discuss government legislation, regulation, policy, contracts, or other business that such government official is in a position to vote upon or otherwise influence.

Marketing Prohibition

Our services may not be used to market to Council Members (e.g., recommend or otherwise push specific products or providers).

Physicians & Other HealthCare Professionals

Physicians participating in clinical trials not yet in the public domain; Clinical Trial Steering Committee and Data Safety Monitoring Board (DSMB) members may not discuss the active trial or the drug that is the subject of the trial; Scientific Advisory Board (SAB) members may not discuss a company’s ongoing clinical trials.
FDA Advisory Committee members may not discuss products or services for which they receives confidential information or makes recommendations.
Pharmaceutical corporations and those working for their benefit may not attempt to influence a health care professional’s decisions about what drugs, devices, or services to prescribe, refer, use, dispense, purchase, lease, or order.
Formulary managers may not discuss their company’s future formulary decisions.

Sales Intelligence Limitation

Our services may not be used to elicit information from Council Members about how to sell to their employers.

Access to a diverse array of specialized expert inputs drives superior decisions in every organizational context: within corporations, by investors and consultancies, and within nonprofits. When decision makers are confident of their decision inputs, they can respond more quickly and creatively to challenges and opportunities. Gerson Lehrman Group provides the benefits of expert interaction along with regular reinforcement of the limits of appropriate engagement.