User Guide To GLG's Compliance Framework

Compliance Philosophy

The value of tapping specialized expertise should be tempered by an awareness of its limitations. Gerson Lehrman Group's (GLG) compliance framework and tools are designed to supplement and enhance the compliance protocols of its clients and to reduce client's exposure to conflicts.

To carry out this philosophy, GLG, the leading platform for primary research, has built proprietary systems to help identify and manage conflicts and to implement your firm's best practices.GLG has also leveraged its experience as a pioneer in its industry to craft risk-reducing rules for expert engagements.

Compliance Systems

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 year¹
• GLG's Contract Management System^SMtracks 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
• GLG's Institutional Registry^SM 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
• GLG's Web site includes tools for companies to register their consulting policies

Project Oversight tools for GLG 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

Client Servicing Rules

Through its experience arranging hundreds of thousands of projects, GLG has developed additional rules of engagement.The following aresome of these rules that govern client use of the GLG Platform:

• Auditors and Finance Professionals: May not discuss financial or accounting issues relating to companies for which they have worked within the last 6 months or which they have audited within the last 2 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: GLG's services may not be used to obtain information from employees of competitors (of the GLG client or any intended recipient of such information).
• Franchisees: May discuss their own franchises, but not their franchisor's strategic plans, new product development, or specific performance data.
• Government Officials: GLG's services may not be used to influence government officials (including any government official,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: GLG's services may not be used to market to Council Members (e.g., recommend or otherwise push specific products or providers).
• Physicians & Other HealthCare Professionals:
  • Clinical Trials: Physicians participating in clinical trials may not discuss patient experience or trial results 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 that Committee receives confidential information or makes recommendations.
  • Avoid Appearances of Kickbacks: 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: GLG's services may not be used to elicit information from Council Members about how to sell to their employers.

1. A small subset of Council Members work through our non-English Web sites.The training module is under development in those languages.
2. Certain C-level executives (President, CEO, CFO, GC,COO) and partners in professional services firms are deemed able to self-consent.