corruption-within-the-pharmaceutical-supply-chain.pdf

8/17/2019 Corruption-within-the-pharmaceutical-supply-chain.pdf

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June 2013

Scoping exerciseCorruption within the pharmaceutical

supply chain to the developing world


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Open Briefing

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Scoping exercise

Corru+tion 5it/in t/e +/-rm-ceutic-l

su++ly c/-in to t/e de.elo+in 5orld


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Contents

Intelligence requirement 1 1

A list of non-governmental organisations currently engaged in work on pharmaceutical and

health service industry corruption, transparency or governance issues relevant to developing

countries.

Actively engaged organisations 3

Other relevant organisations 10

Non-regulatory initiatives 24

Intelligence requirement 2 27

A list of regulations, legislation, codes and standards relating to anti-corruption, anti-riery,

transparency and good governance relevant to the pharmaceutical sector.

International and regional regulations 28

National regulations and laws 33

Intelligence requirement ! !"

An all-source list of #nglish-language pulications on pharmaceutical industry transparency

and corruption issues related to developing countries and emerging economies.

Boos 38

!e"orts 44

#ournal articles $1

Other articles and "resentations %3

&ey co''entators and e("erts %8

Intelligence requirement $ 7%

A high-level comparative assessment of pharmaceutical supply chain corruption risks.

)odalities o* "har'aceutical industry transactions %+

,he "har'aceutical su""ly chain and corru"tion ris 81


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Corruption within the pharmaceutical supply chain to the developing world 1

Intelligence requirement 1

A list of non-governmental organisations currently engaged in work on

pharmaceutical and health service industry corruption, transparency or

governance issues relevant to developing countries.

Analyst’s note: The organisations identified in this section fall broadly into one of the following

categories:

a) rganisations focused on anti-corruption, transparency and good governance research

and policy that may or may not undertake sector-based work on pharmaceuticals and!or

health services.

b)

rganisations focused on global health policy and pharmaceutical industry issues thatundertake work or are well placed to undertake work on anti-corruption and transparency

issues.

c) rganisations focused on global health policy and governance or health service and

pharmaceutical industry policy that have undertaken work or are well placed to undertake

work on aid effectiveness.

nly a minority of organisations listed below primarily focus on anti-corruption in the

pharmaceutical sector. An even smaller proportion of organisations have a dominant focus on the

impact of corruption for developing world access to medicines. rganisations identified through thecollection process have a tendency to pursue research and advocacy at the sectoral level "i.e. health

services more generally). #any civil society organisations "C$s) working on aid effectiveness, heath

policy, and transparency and governance have not necessarily specialised on specific components of

the health sector and instead include pharmaceuticals as part of their broader work on health

services.

%ntergovernmental organisations, such as the &orld 'ealth rganisation "&') and the (nited

ations ffice on *rugs and Crime "(*C), and national aid agencies, such as the (nited

+ingdoms *epartment for %nternational *evelopment "*%*), the (nited $tates Agency for

%nternational *evelopment "($A%*) and the Australian Agency for %nternational *evelopment

"AusA%*), have been strongly involved in health sector anti-corruption initiatives. $ome of their work

is highlighted across the various sections of this report however the organisations themselves are

not listed in this section, as they are not /s. They are provided in the diagram overleaf for

reference.


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2 pen 0riefing

ig 1. +ey international and regional organisations

Two of the resources created during the collection and processing stages of this contract have been

made publicly available at:

1harmaceutical anti-corruption pro2ect custom /oogle search engine

http:!!bit.ly!pharmasearch

This custom /oogle search engine includes 34 high-level (56s of relevant sources and organisations

for more effective and targeted research in the future. The custom search engine will generally

return more relevant results than standard /oogle searches, as it only searches the included (56s

and not the wider internet.

1harmaceuticals monitor Twitter list

http:!!bit.ly!pharmamonitor

This Twitter list is made up of 78 accounts that would be helpful to monitor for anti-corruption

issues in the pharmaceutical sector, including all the organisations identified in the following pages.


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Corruption within the pharmaceutical supply chain to the developing world !

Actively engaged organisations

"rganisation #enter for $lobal %evelopment

&ocation &ashington *C, (nited $tates

'ebsite http:!!www.cgdev.org!

()itter handle 9C/*ev

*elevant +*&s

http:!!www.cgdev.org!blog!corruption-indias-health-sector-lets-look-bigger-

picture

http:!!www.cgdev.org!!topics!globalhealth

http:!!www.cgdev.org!topics!transparency

C/* has a prominent and visible presence on global health policy and transparency issues with

offices in both the (nited $tates and ;urope. Although C/*s commentary on health sector

corruption is limited and their focus within global health policy is on foreign-aid funded health

services, the dual focus on health and transparency puts C/* in a strong position to participate in

dialogue on anti-corruption issues in the health sector.

"rganisation #hr. ichelsen Institute

&ocation 0ergen, orway

'ebsite http:!!www.cmi.no!

()itter handle -

*elevant +*&s http:!!www.cmi.no!research!themes!


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/ pen 0riefing

"rganisation 0uropean ealthcare raud #orruption 3et)or4

&ocation ;(

'ebsite http:!!www.ehfcn.org!

()itter handle -

*elevant +*&s http:!!www.ehfcn.org!what-we-are-about!about-fraud-corruption-waste

;'C is a membership based organisation made up of insurance companies, /s and government

agency stakeholders with a primary focus on healthcare fraud in ;urope. ;'C participates in

awareness-raising campaigns, produces publications and runs training courses and seminars. &hile

the ;'C is not working in a developing country conte>t, its ;urope wide focus does mean some of

its work is on ;astern ;uropean health sector corruption hotspots.

"rganisation $lobal Integrity


'ebsite http:!!www.globalintegrity.org!

()itter handle 9/lobal%ntegrity

*elevant +*&s http:!!www.globalintegrity.org!node!48?

/lobal %ntegrity works on open source information and communications technology to improve

accountability and transparency. ;very year /% produces a /lobal %ntegrity 5eport reviewing national

level transparency in public procurement processes, media freedom, asset disclosure and conflicts

of interest regulations. /lobal %ntegrity does have some limited coverage of health sector corruption

with the focus on fficial *evelopment Aid "*A) health service provision in African nations.

"rganisation $lobal 5harma ealth und

&ocation /iessen, /ermany

'ebsite http:!!www.gphf.org!

()itter handle 9/1'

*elevant +*&s http:!!www.gphf.org!web!en!historie!lpro2.htm

/1' is a / purely focused on the proliferation of counterfeit medicines. The organisation has

developed a mobile mini-laboratory for rapid drug @uality verification and easy counterfeit

medicines detection. The laboratories are deployed in a number of countries across the Americas,

Asia and Africa, with the largest numbers in $ub-$aharan Africa.


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"rganisation eartfile

&ocation %slamabad, 1akistan

'ebsite http:!!www.heartfile.org!

()itter handle 9'eartfileTweets

*elevant +*&shttp:!!www.heartfile.org!pdf!Corruption.pdf

http:!!www.heartfile.org!pdf!#(&1T%.pdf

'eartfile is a high-profile 1akistani / working on health policy and health systems analysis. %t has

received funding for health sector anti-corruption work from the 1artnership for Transparency und.

The founder, *r $ania ishtar, has published a number of papers on health governance and

corruption.

"rganisation International 3et)or4 for *ational +se of %rugs

&ocation Arlington, (nited $tates

'ebsite http:!!www.inrud.org!

()itter handle -

*elevant +*&s http:!!coveo.msh.org!C;$7!Coveo!$earch.asp>


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7 pen 0riefing

"rganisation anagement 8ciences for ealth

&ocation Cambridge, (nited $tates

'ebsite http:!!www.msh.org!

()itter handle 9#$''ealth%mpact

*elevant +*&s

http:!!www.msh.org!our-work!health-system!pharmaceutical-management

http:!!www.msh.org!searchB-E8?submit.yB-

44

http:!!www.msh.org!blog!F44!F7!4E!health-is-wealth-especially-in-fragile-

states

#$' works in the area of improving health systems in developing countries. The organisation has a

number of pro2ect and research platforms on health system governance. (nder the umbrella of

pharmaceutical management, #$' work on selection and rational use of medicines, information

management systems and pharmaceutical regulation. Although work is not directly focused on

corruption, it is cited as a recurring theme in institutional health system settings.

"rganisation edecins 8ans rontieres

&ocation /eneva, $witGerland "international office)

'ebsite http:!!www.msf.org!

()itter handle 9#$access

*elevant +*&shttp:!!www.msfaccess.org!

http:!!www.msfaccess.org!search


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"rganisation "pen 8ociety oundation

&ocation ew Hork, (nited $tates

'ebsite www.opensocietyfoundations.org!

()itter handle 9pen$ociety

*elevant +*&shttp:!!www.opensocietyfoundations.org!topics!accountability-health

http:!!www.opensocietyfoundations.org!topics!anticorruption

pen $ociety oundation has supported a number of transparency and accountability campaigns

including the ;>tractive %ndustries Transparency %nitiative ";%T%). &hile health publications and

campaigns are focused more generally on human rights and health sector governance, pen $ociety

oundation does have a 'ealth inancing section, which has cross-cutting agendas across the

general governance, accountability and anti-corruption work programmes.

"rganisation 5artnership for (ransparency und


'ebsite http:!!ptfund.org!

()itter handle 91Tund

*elevant +*&s

http:!!ptfund.org!F4!F=!controlling-healthservices-corruption-odisha-india!

http:!!ptfund.org!F4!F=!monitoring-medicines-procurement-philippines!

http:!!ptfund.org!F4!F=!corruption-drug-trials-kerala-india!

http:!!ptfund.org!publications!case-studies-by-sector-test!

1artnership for Transparency und provides grant support to a number of initiatives to improve

transparency and anti-corruption initiatives in key developing countries. /rant recipient pro2ects are

published as case studies. A number of case studies have been produced on health sector anti-

corruption initiatives from %ndia, epal and 1hilippines.


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pen 0riefing

"rganisation *egional Anti-#orruption Initiative

&ocation $ara2evo, 0osnia and 'erGegovina "secretariat)

'ebsite http:!!www.rai-see.org!

()itter handle -

*elevant +*&s

http:!!www.rai-see.org!news!world!78-thank-you-i-don-t-take-bribes-an-

initiative-to-remedy-corruption-in-the-slovak-health-care-sector.html

http:!!www.rai-see.org!events!upcoming-events!?8II-global-anti-corruption-

and-corporate-compliance-for-pharma-september-44-4?-F4?-berlin-

germany.html

http:!!www.anticorruption-croatia.org!home!news-from-croatia!4I-minister-

?8F-family-doctors-suspected-of-bribery-health-care-not-in-danger

#ade up of nine $outheast ;uropean member countries, the 5A% is the primary anti-corruption

forum in the region. The 5A% process engages with governments, local and international civil society

organisations, bilateral aid agencies and international organisations to combat corruption. Although

5A% has had limited focus on health sector corruption, the hosting of an upcoming /lobal Anti-

corruption and Corporate Compliance for 1harma event in $eptember F4? may indicate more

attention is being paid to pharmaceutical sector corruption.

"rganisation (ransparency International

&ocation 0erlin, /ermany "secretariat)

'ebsite http:!!www.transparency.org!

()itter handle 9anticorruption

*elevant +*&s

http:!!www.transparency.org!topic!detail!health!18

http:!!www.transparency.org!research!gcr!gcrhealth

http:!!www.tisrilanka.org!.php!pro2ects!health

http:!!www.spidercenter.org!pro2ects!promoting-social-accountability-health-

sector-northern-uganda

http:!!www.ti-bangladesh.org!oldweb!about!Colin+no>-pap-#arFE.pdf

http:!!www.tikenya.org!inde>.php


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Corruption within the pharmaceutical supply chain to the developing world ;

Transparency %nternational is one of the leading / networks on transparency and anti-corruption

globally. %n FF7, T% published the regularly cited Global Corruption Report 2006: Corruption and

Health and individual country chapters have continued to participate in research and working groups

on health sector corruption. T% also helps run and fund the %nternational Anti-corruption Conference

Council, which has previously facilitated forums on health sector corruption.

"rganisation +/ Anti-corruption *esource #entre

&ocation 0ergen, orway

'ebsite http:!!www.u=.no!

()itter handle 9(=AC5C

*elevant +*&s

http:!!www.u=.no!themes!health-sector!

http:!!www.u=.no!publications!good-governance-for-medicines-initiatives-

e>ploring-lessons-learned!

http:!!www.u=.no!publications!corruption-in-the-health-sector-!

(= Anti-corruption 5esource Centre has published a number of e>tensive and high-level reports on

health sector corruption over the last decade and identifies the health sector as one of its key

thematic areas for research. ther organisations regularly syndicate and use recent (= reports on

health sector corruption as the leading work on health sector anti-corruption and good governance.

5esearch and policy authors are leading commentators on health sector corruption issues. (= also

operates training courses on corruption in the health sector for (= development partner country

members.


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1isting news

stories. Carries a section on corrupt practices by the pharmaceutical sector, which contains some

relevant material.

"rganisation AA**I=" =rasil

&ocation $Jo 1aulo, 0raGil

'ebsite http:!!www.amarribo.org.br!

()itter handle 9A#A55%0

*elevant +*&s http:!!www.amarribo.org.br!pt05!iniciativas!brasilemandamento

A#A55%0 0raGil is an / campaigning and advocating on anti-corruption issues in 0raGil. 'elps

support the %nternational Anti-corruption Conference Council. 6imited coverage of health

corruption issues.


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"rganisation American 0nterprise Institute


'ebsite http:!!www.aei.org!

()itter handle 9A;%

*elevant +*&s

http:!!www.aei.org!policy!health!global-health!

http:!!www.aei.org!article!health!global-health!the-great-pharmaceuticals-

scam!

A;% has a strong global health policy portfolio, including work on counterfeit medication and

corruption impacts on aid effectiveness. 5oger 0ate is the key A;% resident scholar writing on these

issues co-authored a FF7 paper titled Tariffs, Corruption and Other Impediments to Medicinal ccess

in !e"elopin# Countries: $ield %"idence with Africa ighting #alaria.

"rganisation Anti-corruption *esearch 3et)or4

&ocation 0erlin, /ermany

'ebsite http:!!corruptionresearchnetwork.org!

()itter handle -

*elevant +*&s

http:!!corruptionresearchnetwork.org!topics!health

http:!!corruptionresearchnetwork.org!datasets!where-the-bribes-are-

interactive-database

http:!!corruptionresearchnetwork.org!datasets!F44-bribe-payers-inde>

acilitated by Transparency %nternational, the Anti-corruption 5esearch etwork carries a number of

health related anti-corruption material sources and links to anti-bribery sources and health sector

data sets.


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12 pen 0riefing

"rganisation =asel Institute on $overnance

&ocation /eneva, $witGerland

'ebsite http:!!www.baselgovernance.org

()itter handle -

*elevant +*&s

http:!!www.baselgovernance.org!gov!health-systems!

http:!!www.baselgovernance.org!events!article!generics-and-biosimilars-

affordable-medicine!ttnewsKback1idLB?8c'ashBEba88bIE8

http:!!www.baselgovernance.org!events!article!philanthropy-in-global-helath-

governance-and-effectiveness-

criteria!ttnewsKback1idLB=4c'ashB?c4e4E?3?7

0asel %nstitute on /overnance has a governance and anti-corruption division. This division has a

thematic research area on health systems. Although the ma2ority of health governance and anti-

corruption work was carried out prior to FF3, the institute still has strong research capacity on

health sector transparency issues and did hold an event on pharmaceutical generics.

"rganisation =usiness Anti-corruption 5ortal

&ocation Copenhagen, *enmark

'ebsite http:!!www.business-anti-corruption.org!

()itter handle -

*elevant +*&shttp:!!www.business-anti-corruption.org!anti-corruption-tools-

inventory!sector-specific-anti-corruption-resources!other-sectors!

This research portal is geared towards businesses looking for tools to assist with due diligence and

integrity systems. The portal contains helpful country transparency profiles, guides on bribery laws

and cross sector lists of anti-corruption initiatives.


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Corruption within the pharmaceutical supply chain to the developing world 1!

"rganisation #enter for edicine in the 5ublic Interest


'ebsite http:!!www.cmpi.org!

()itter handle 9drugwonks

*elevant +*&s

http:!!www.cmpi.org!in-the-news!in-the-news!measuring-responsibility-in-big-

pharma!

http:!!www.cmpi.org!in-the-news!in-the-news!talking-turkey-about-access-to-

medicines!

C#1% is a C$ working on ($ domestic and global health policy issues. C#1% aggregates relevant

pharmaceutical-industry news and undertakes profile work on the Access to #edicines %nde>.

"rganisation #enter for 8trategic International 8tudies #8I8


'ebsite www.csis.org!

()itter handle 9C$%$

*elevant +*&s

http:!!www.smartglobalhealth.org!

http:!!csis.org!program!global-health-policy-center

https:!!csis.org!files!publication!4FI#orrison5ighting/lobalund&eb.p

df

*espite having a global healthcare programme, C$%$ has limited coverage of healthcare sector

corruption and its global healthcare policy work is somewhat preoccupied with domestic ($

dimensions and security paradigm focused. The $mart /lobal 'ealth portal carries a range of

publications on global health issues such as health diplomacy and security linkages to health policy.

C$%$ did publish some commentary on corruption issues arising from /lobal und programmes in

F44.


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1/ pen 0riefing

"rganisation #hatham ouse > #entre on $lobal ealth 8ecurity

&ocation 6ondon, (nited +ingdom

'ebsite http:!!www.chathamhouse.org!research!global-health

()itter handle 9C'/lobal'ealth

*elevant +*&s

http:!!www.chathamhouse.org!research!global-health-security!current-

pro2ects!identifying-sustainable-methods-improving-global-he

http:!!www.chathamhouse.org!research!global-health!current-

pro2ects!counterfeit-medicines

Chatham 'ouses Centre on /lobal 'ealth $ecurity has three key thematic research areas: access to

health products, transborder disease threats and international health governance. The centre

carried out work in F4F on counterfeit drugs with the publication of a briefing paper and event.

Although the centre has not pursued health or pharmaceutical sector corruption and transparency

issues under its Access to #edicines platform, its ancillary work on global health issues does focus

on researching mechanisms that assist in the provision of medicines in developing countries.

"rganisation 0cumenical 5harmaceutical 3et)or4

&ocation airobi, +enya

'ebsite http:!!www.epnetwork.org!

()itter handle -

*elevant +*&s

http:!!www.epnetwork.org!access-to-and-rational-use-of-medicines

http:!!www.epnetwork.org!pharmalink-newsletter

http:!!www.epnetwork.org!epn-members

;1 is a large network of Christian /s researching and campaigning on pharmaceutical access

issues. The ;1 has strong representation across $ub-$aharan Africa and collaborate with 'ealth

Action %nternational "'A%) Africa.


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"rganisation 0quinet Africa

&ocation 'arare, Mimbabwe

'ebsite http:[email protected]!

()itter handle -

*elevant +*&shttp:[email protected]!bibl!discussion.php

http:[email protected]!workgovernance.php

;@uinet Africa, the 5egional etwork on ;@uity in 'ealth in $outhern Africa, is an / working on

social 2ustice and e@uality in the health sector. ne of its key thematic areas of work is on health

governance, which has some incidental coverage of anti-corruption. ;@uinet produces both original

research material and is also an aggregator of relevant papers and policy on health governance.

"rganisation 0uropean 5ublic ealth Alliance

&ocation 0russels, 0elgium

'ebsite http:!!www.epha.org!

()itter handle -

*elevant +*&s http:!!www.epha.org!a!??

$yndicates some material on health services sector corruption, though work is primarily ;( focused.

"rganisation ood and %rug &a) Institute


'ebsite http:!!www.fdli.org!

()itter handle -

*elevant +*&s

http:!!www.fdli.org!resources!resources-order-bo>-detail-view!why-self-

regulation-does-not-work-resolving-prescription-corruption-caused-by-

e>cessive-gift-giving-by-pharmaceutical-manufacturers

The ood and *rug 6aw %nstitute facilitates member education and discussion of regulatory issues

relevant to the health and pharmaceutical sector. Carries have some ($ specific materials on

corruption in the pharmaceutical sector related to prescription corruption.


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17 pen 0riefing

"rganisation $=# ealth


'ebsite http:!!www.gbchealth.org!

()itter handle 9/0C'ealth

*elevant +*&shttp:!!www.gbchealth.org!asset!session-the-business-of-health-

diplomacy!


23/96


"rganisation $lobal ealth 5rogress

&ocation -

'ebsite http:!!www.globalhealthprogress.org!

()itter handle 9/lobal'ealth

*elevant +*&s

http:!!www.globalhealthprogress.org!search!node!corruption

http:!!www.globalhealthprogress.org!perfect-prescription

http:!!www.globalhealthprogress.org!kenyan-health-office-says-health-aid-

best-channeled-through-governments

The /lobal 'ealth 1rogress initiative includes collaboration between research-based pharmaceutical

companies and global health analysts focused on access to medicine and healthcare in the

developing world issues. /lobal 'ealth 1rogress carries developing country health governance

reports.

"rganisation ealth and ragile 8tates 3et)or4


'ebsite www.healthandfragilestates.org!

()itter handle -

*elevant +*&s

http:!!www.healthandfragilestates.org!inde>.php.php


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25/96

Corruption within the pharmaceutical supply chain to the developing world 1;

"rganisation enry ?aiser amily oundation


'ebsite http:!!kff.org!

()itter handle 9+aiseramound

*elevant +*&shttp:!!kff.org!news-summary!daily-report-global-health-conversations-health-

sector-corruption!

'enry +aiser amily oundation undertakes analysis on a range of ($ and international healthcare

issues. Their /lobal 'ealth 1olicy platform is dominated by health diplomacy issues from a ($

perspective and understanding health policy ob2ectives and aid effectiveness in terms of Aids,

tuberculosis and malaria initiatives. Aid effectiveness work does appear to raise @uestion about

corruption.

"rganisation uman *ights ouse 3et)or4 +ganda

&ocation +ampala, (ganda

'ebsite http:!!humanrightshouse.org!

()itter handle -

*elevant +*&s http:!!humanrightshouse.org!Articles!3III.html

'5' "(ganda) carries very limited material on health sector corruption but is located in a strategic

location in terms of contentious issues around '%O!Aids pharmacy issues.

"rganisation Independent Advocacy 5ro@ect

&ocation igeria

'ebsite http:!!iap-nigeria.org!

()itter handle -

*elevant +*&s http:!!iap-nigeria.org!D!publications!=8=F4E733

%A1 is igeriaPs leading anti-corruption monitoring organisation. %A1 has participated in programmes

e>amining the link between '%O!Aids funding and corruption, titled 1romoting Accountability and

Transparency in '%O unding "1AT'). The outcome of 1AT' is published in a report Transparenc&

!eficit: report on HI'(ids $undin# in )i#eria .


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2


27/96


"rganisation "fam International

&ocation >ford, (nited +ingdom "secretariat)

'ebsite http:!!www.o>fam.org!

()itter handle 9>fam

*elevant +*&s

http:!!www.o>fam.org!en!campaigns!health-education!health

http:!!www.o>fam.org!en!policy!bp48-blind-optimism

http:!!www.o>fam.org!en!pressroom!pressrelease!F44-44-47!global-aid-

agreement-knife-edge

http:!!www.o>fam.org!sites!www.o>fam.org!files!eye-on-the-ball-medicine-

regulation-FF44-en.pdf

>fam %nternational and its regional offices have consistently participated in transparency initiativessuch as ;%T% and 1ublish &hat Hou 1ay campaigns. They also undertake policy advocacy work on aid

effectiveness. &hile >fam has not carried out work on health and pharmaceutical sector corruption

it has done work on substandard medicines and is likely to be interested in future work on anti-

corruption in aid health programmes.

"rganisation 5harmaceutical *esearch and anufacturers of America


'ebsite http:!!www.phrma.org!

()itter handle 91h5#A

*elevant +*&shttp:!!www.phrma.org!media!releases!key-us-health-industries-outline-si>-

point-plan-improved-health-economic-growth-asia-

Connected with /lobal 'ealth 1rogress. #ostly focused on intellectual property protection and

counterfeit drug issues.


28/96

22 pen 0riefing

"rganisation 5harmaceutical 8ecurity Institute

&ocation 6ondon, (nited +ingdom and 'ong +ong, China

'ebsite http:!!www.psi-inc.org!inde>.cfm

()itter handle -

*elevant +*&s

http:!!www.psi-inc.org!counterfeit$ituation.cfm

http:!!www.psi-inc.org!geographic*istributions.cfm

http:!!www.psi-inc.org!safe#edicines.cfm

1$% is a not-for-profit membership based organisation campaigning on counterfeit medicine issues

and safe medicines. 1$% membership includes 7 ma2or pharmaceutical manufacturers alongside key

government agencies.

"rganisation 5opulation 8ervices International


'ebsite http:!!www.psi.org!

()itter handle 91$%impact

*elevant +*&s http:!!www.psi.org!impact-magaGine!F44!F8!susan-brems-phd

1$% has a strong presence in health policy issues in developing countries. 1$% is recipient of ma2or

grants from donors like The /lobal und to ight Aids, Tuberculosis and #alaria, ($A%* and the

/ates oundation. $ome of this funding is issued as sub-awards to local organisations to achieve

national health impact from the community level up. Although very little engagement on corruption

issues, 1$% appears to be interested in health governance issues.

"rganisation 5ublic ealth oundation of India

&ocation ew *elhi , %ndia

'ebsite http:!!www.phfi.org!

()itter handle -

*elevant +*&s

http:!!www.phfi.org!our-activities!research-a-centres!key-areas!health-

system-and-policy!F3-transparency-and-accountability-in-drug-procurement-

and-distribution-in-india

1ublic 'ealth oundation %ndia has undertaken a number of studies on inefficiencies and ine@uities

in %ndiaPs public health financing and delivery. A number of these studies consider transparency and

accountability procedures in pharmaceutical and health service procurement.


29/96


"rganisation (race International

&ocation (nited $tates and (nited Arab ;mirates

'ebsite http:!!www.traceinternational.org!

()itterhandle

9T5AC;%nc

*elevant

+*&s

http:!!www.traceinternational.org!+nowledge!Compendium!$earchCompendium.

html

Trace %nternational is a not-for-profit resource service that provides anti-bribery compliance

solutions to companies. The Trace Compendium contains multiple case studies entries on bribery

actions taken against pharmaceutical companies.


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2/ pen 0riefing

on-regulatory initiatives

"rganisationAsian %evelopment =an4B"0#% Anti-corruption Initiative for Asia and the

5acific

&ocation %nternational

'ebsite http:!!www.oecd.org!site!adboecdanti-corruptioninitiative!

()itter handle -

The A*0!;C* initiativePs ?4 member economies in the Asia-1acific region have 2ointly developed

the Anti-corruption Action 1lan for Asia and the 1acific and work together towards its

implementation. The action plan sets out the goals and standards for sustainable safeguards against

corruption in the economic, political and social spheres of the countries in the region.

"rganisation edicines (ransparency Alliance

&ocation Amsterdam, The etherlands

'ebsite http:!!www.medicinestransparency.org!

()itter handle -

*elevant +*&s

http:!!www.medicinestransparency.org!key-issues!transparency-and-

accountability!

http:!!www.medicinestransparency.org!about-meta!core-principles!

http:!!www.medicinestransparency.org!fileadmin!uploads!*ocuments!#eTAre

viewpilot.pdf

The #eTA pro2ect is a health services and pharmaceutical transparency pro2ect supported by the

&orld 0ank, &' and *%*. The pro2ect aims to improve information e>change to address medical

access and corruption issues. A pilot programme was developed and rolled out in /hana, Nordan,

+yrgyGstan, 1eru, 1hilippines, (ganda and Mambia. The website contains a number of guides, reports

and policy documents relevant to pharmaceutical and health sector anti-corruption work.

ig !. +ey non-regulatory initiatives


31/96


"rganisation (ransparency and Accountability Initiative


'ebsite http:!!www.transparency-initiative.org!

()itter handle 9TA%nitiative

*elevant +*&shttp:!!www.transparency-initiative.org!reports!donor-aid-new-frontiers-in-

transparency-and-accountability

(ndertaking similar work to /lobal %ntegrity in terms of working with technology to improve

transparency, though no specific work on health sector transparency. 'as published material on

international aid transparency initiatives.

"rganisation +3 $lobal #ompact


'ebsite http:!!www.unglobalcompact.org!

()itter handle 9globalcompact

*elevant +*&s

http:!!www.unglobalcompact.org!%ssues!transparencyanticorruption!

http:!!www.unglobalcompact.org!docs!issuesdoc!Anti-

Corruption!(/CAntiCorruption5eporting.pdf

http:!!www.unglobalcompact.org!docs!issuesdoc!Anti-

Corruption!ightingCorruption$upplyChain.pdf

http:!!unpsi.org!about-psi!

The ( /lobal Compact partners with (*C, Transparency %nternational, the %nternational

Chamber of Commerce, the &orld ;conomic orum 1artnership Against Corruption %nitiative and the

&orld 0ank %nstitute to provide a forum and opportunities for businesses to take up anti-corruption

agendas. The /lobal Compact Anti-Corruption principles are derived from the ( Convention

against Corruption.


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27 pen 0riefing

"rganisation 'orld 0conomic orum 5artnering Against #orruption Initiative


'ebsite http:!!www.weforum.org!

()itter handle -

*elevant +*&shttp:!!www.weforum.org!issues!partnering-against-corruption-

initiativeD1AC%sectors

1AC% is an international anti-corruption initiative of the &orld ;conomic orum. (nfortunately there

is no pharmaceutical representation on 1AC% despite the initiative being globally relevant in the anti-

corruption field.

"rganisation 'orld ealth "rganisation $ood $overnance for edicines 5rogramme


'ebsite http:!!www.who.int!medicines!ggm!en!

()itter handle 9&'

*elevant +*&s

http:!!www.who.int!medicines!areas!policy!goodgovernance!en!

http:!!www.who.int!medicines!areas!policy!goodgovernance!documents!en!in

de>.html

http:!!www.who.int!medicines!areas!policy!goodgovernance!implementation!e

n!inde>.html

%n FF=, &' launched the /ood /overnance for #edicines "//#) programme with the aim of

addressing corruption in the pharmaceutical sector by promoting good governance and regulatory

system strengthening. The programme is broken into three phases: national transparency

assessment, development of a national //# framework and implementation of a national //#

programme. The &' publishes transparency assessments and progress reports online. Alongside

#eTA, //# is one of the key sector-based initiatives addressing corruption in the pharmaceutical

sector.


33/96


Intelligence requirement 2

A list of regulations, legislation, codes and standards relating to anti-

corruption, anti-bribery, transparency and good governance relevant to

the pharmaceutical sector.

Analyst note: Anti-corruption and bribery reform over the last decade has been preoccupied with

domestic criminalisation of bribing public officials at home or abroad. %nternational framework

conventions generally re@uire signatories to implement domestic anti-bribery legislation and

participate in e>ternal reviews of their anti-corruption legislation by international organisations and

working groups.

ational laws on bribery of foreign public officials are an important mechanism to discouragee>porters, including those in the pharmaceutical sector, from bribing public officials in importer

countries, even where the laws in the importing country do not criminalise active corruption. or

e>ample, pharmaceutical e>porter companies domiciled in the (nited +ingdom, (nited $tates,

Canada, %srael, $ingapore or Napan whose staff offer or pay bribes for commercial benefit could face

enforcement action in their home country for bribing a foreign public official.

&hile international framework conventions have instilled a level of commonality in different

national anti-bribery regimes, key differences in domestic regulations e>ist. These include: scope

"public and!or private sector bribery), nature "active or passive Q active is the bribe offer and passive

is the bribe receipt), liability of companies and due diligence re@uired, and e>traterritoriality "scope

of 2urisdiction).

The list of regulations in the following section focuses on international and regional framework

conventions or agreements and national regulations. ational regulations primarily include laws

that criminalise bribery, though there are some e>amples of pharmaceutical specific regulations. or

detailed information on pharmaceutical regulations in developing countries that govern medicine

assessment, procurement, distribution, licensing and marketing see the &'s /ood /overnance of

#edicines 1hase 4 ational Transparency Assessment Country 5eports available at

http:!!bit.ly!ggmcountryreports.


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2 pen 0riefing

%nternational and regional regulations

Instrument +nited 3ations #onvention against #orruption

Curisdiction %nternational

Application 4=F signatories 47I parties:http:!!www.unodc.org!unodc!en!treaties!CAC!signatories.html

'ebsite

http:!!www.unodc.org!documents!treaties!(CAC!1ublications!Convention!F3-

8FF7;.pdf

http:!!www.business-anti-

corruption.com!fileadmin!userupload!word!(CAC$ummary.doc

;ntering into force in FF8, the (CAC is one of the primary international framework mechanisms

to confront corruption. Convention signatories commit to establishing domestic anti-corruption,

anti-money laundering and anti-bribery policies and laws. $ignatories also commit to international

cooperation in asset freeGing and recovery. Articles 4F and 4? re@uire state parties to implement

public reporting measures and disclosure regimes.

&hile the (CAC shares a number of overlapping provisions with the ;C* Convention, there

are some important differences. or e>ample, (CAC contains provisions that state parties

consider implementing measures preventing and criminalising private sector briberies.

*espite forming an important international framework for developed and developing countries to

build domestic anti-corruption legislation on, the voluntary nature of the review mechanism to

assess $tate 1arty implementation remains a ma2or weakness of the convention.

Instrument"0#% #onvention on #ombating =ribery of oreign 5ublic "fficials in

International =usiness (ransactions

Curisdiction %nternational framework convention re@uiring domestic regulation

Application;C* member 2urisdictions and some non-;C* members:

http:!!www.oecd.org!daf!anti-bribery!antibriberyconventionratification.pdf

'ebsite http:!!www.oecd.org!daf!anti-bribery!anti-briberyconvention!?3F3F==.pdf

The ;C* is an international anti-bribery regime aimed at criminalising bribery of foreign public

officials in international business transactions. The ;C* Convention is much narrower than the

(CAC in terms of the modalities of corruption and money laundering covered. A number of ;C*

recommendations complement the ;C* anti-bribery regime, which are of relevance to the

pharmaceutical and health services sector including the 5ecommendation on Anti-corruption

1roposals for Aid-funded 1rocurement and the ;C* 5ecommendation on 0ribery and fficially

$upported ;>port Credits.


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Instrument0+ #onvention on the ight against #orruption involving "fficials of the

0uropean #ommunities or "fficials of ember 8tates of the 0+ 1;;9

Curisdiction ;uropean (nion

Application ramework decision for ;( member states

'ebsite

http:!!eur-

le>.europa.eu!6e>(ri$erv!6e>(ri$erv.do

http:!!eur-

le>.europa.eu!6e>(ri$erv!6e>(ri$erv.do


36/96

!


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Corruption within the pharmaceutical supply chain to the developing world !1

Instrument8outhern African %evelopment #ommunity 8A%# 5rotocol Against

#orruption

Curisdiction

$outh African state signatories: Angola, 0otswana, *emocratic 5epublic of Congo,

6esotho, #alawi, #auritius, #oGambi@ue, amibia, $eychelles, $outh Africa,

$waGiland, TanGania, Mambia and Mimbabwe

'ebsitehttp:!!www.2us.uio.no!english!services!library!treaties!F=!=-F=!sads-against-

corruption.>ml

Adopted in FF4, the $A*C 1rotocol Against Corruption calls on signatories to promote the

development of anti-corruption mechanisms at the national level, cooperation in the fight against

corruption by state parties and harmonise anti-corruption national legislation in the region.

Instrument Inter-American #onvention Against #orruption

Curisdiction Americas

Application$ignatory countries of the rganiGation of American $tates "A$):

http:!!www.oas.org!2uridico!english!$igs!b-83.html

'ebsitehttp:!!www.oas.org!2uridico!english!Treaties!b-83.html

http:!!www.oas.org!2uridico!english!mesicicintroen.htm

The %ACAC was one of the first international instruments on corruption. The convention re@uires

signatories to foster international cooperation and implement criminal laws dealing withgovernment official corruption, preventative measures and identification and e>tradition. (nder the

convention the #echanism for ollow-up on the %mplementation of the %nter-American Convention

against Corruption "#;$%C%C) has been established to evaluate implementation of the treaty.


38/96


39/96

Corruption within the pharmaceutical supply chain to the developing world !!

ational regulations and laws

Instrument =ribery Act 2panded the scope of corruptionregulation to outside of %reland. 0ribery of foreign government official is now covered within

%relands anti-corruption laws and applies to all persons and companies having a connection with the

state.


40/96

!/ pen 0riefing

Instrument #riminal #ode 8ection 2;; and #riminal #ode 8ection !!1

Curisdiction /ermany

'ebsitehttp:!!www.gesetGe-im-internet.de!englischstgb!englischstgb.htmlDp37

http:!!www.gesetGe-im-internet.de!englischstgb!englischstgb.htmlDp=FI

According to the ;C* &orking /roup on 0ribery, /ermany has assumed a leading position in the

investigation and prosecution of foreign bribery cases. /ermanyPs criminal code contains a number

of provisions criminalising both active and passive bribery of domestic and foreign public officials.

/erman law does not recognise corporate criminal liability in bribery cases and only individuals can

be sub2ect to criminal prosecutions. 'owever, a company can be held liable under /ermanys

Administrative ffenses Act for an act of corruption committed by a person with managerial

responsibility for the company if, as a result of the offense, duties of the company were violated or

the company was enriched.

Instrument ederal Act against +nfair #ompetition and 8)iss #riminal #ode

Curisdiction $witGerland

'ebsitehttp:!!www.seco.admin.ch!themen!FF7=8!FF78I!FF78E!F4?E8!inde>.htmltraterritorial

application, though does not cover foreign subsidiaries. A company can be held liable for certain

criminal offenses if it fails to institute all reasonable organisational measures to prevent bribery and

corruption. ew legislation is currently proposed in $witGerland that would make all forms of

bribery, including bribery provisions for the private sector, sub2ect to criminal investigations.

Instrument oreign #orrupt 5ractices Act

Curisdiction (nited $tates

Application (nited $tates with some e>traterritorial application

'ebsitehttp:!!www.2ustice.gov!criminal!fraud!fcpa!docs!fcpa-english.pdf

http:!!www.2ustice.gov!criminal!fraud!fcpa!

The C1A is the (nited $tatesP key anti-corruption and anti-bribery legislation. The act prohibits

bribery of foreign officials and employees who work for foreign governments and applies to public

or private ($ organisations and legal persons, including a foreign person or firms, if they commit a

prohibited act in the (nited $tates. oreign subsidiaries are also captured under the legislation. The

C1A re@uires companies to maintain records on anti-corruption due diligence and internal controlsto prevent corrupt behavior. The C1A does not however, criminalise passive corruption.


41/96


Instrument 5hysician inancial (ransparency *eports 8unshine Act

Curisdiction (nited $tates

'ebsite http:!!thomas.loc.gov!cgi-bin!@uery!G


42/96

!7 pen 0riefing

Instrument +nfair #ompetition 5revention Act

Curisdiction Napan

'ebsite http:!!www.wipo.int!wipole>!en!details.2sptraterritorial effect as the laws apply to all those residing in China,

regardless of their nationality to all Chinese citiGens living abroad and to companies and

institutions registered under Chinese law, including foreign owned enterprises operating in the

country, 2oint ventures and Chinese companies overseas. The 15C regulators are apparently

strengthening their investigation and prosecution of bribery cases, pursuing more than 4F,FFF

private sector bribery cases in F4F.


43/96


Instruments5revention of #orruption Act 1; and 5revention of =ribery of oreign

5ublic "fficials and "fficials of 5ublic International "rganisations =ill

Curisdiction %ndia

'ebsite

http:!!www.prsindia.org!uploads!media!0ribery!1reventionSFofSF0ribery,

SF7SFofSFF44.pdf

http:!!www.prsindia.org!billtrack!the-prevention-of-bribery-of-foreign-public-

officials-and-officials-of-public-international-organisations-bill-F44-47F4!

%n F44, the government put forward the 1revention of 0ribery of oreign 1ublic fficials and

fficials of 1ublic %nternational rganisations 0ill. The proposed legislation criminalises bribery of

foreign public officials or officials of public organisation and makes provision for fines and

imprisonment "from si> months to seven years). The proposed bill which has been sub2ect to

significant debate and contestation since F44, as it would significantly modernise %ndiaPs e>isting

1revention of Corruption Act "4E33). Currently the 1CA attaches criminal liability under the %ndian1enal Code to both public and private sector corruption but has not provided for the criminalisation

of bribing a foreign public official.

Instrument =raDilian #riminal #ode and Anti-#orruption =ill 727B2


44/96

! pen 0riefing

Intelligence requirement !

An all-source list of ;nglish-language publications on pharmaceutical

industry transparency and corruption issues related to developing

countries and emerging economies.

Analyst 3ote: %n FF7, Transparency %nternational published the Global Corruption Report 2006 ,

which focused on corruption and health "see http:!!bit.ly!globalcorruptionreport). *uring FF7-FI,

several academics and C$s followed up with a number of articles and reports on pharmaceutical

and health sector corruption. 'owever, the FF3-4? timeframe re@uested by the client means that

these documents are not listed in the following section. urthermore, the &' /ood /overnance

for #edicines programme was started in FF= and so early documentation is not included for the

same reason.

0ooks

(itle A 5ractical Approach to 5harmaceutical 5olicy

Author Andreas $eiter

5ublisher &orld 0ank

Eear F4F

0pense ree

+*& http:!!www-

wds.worldbank.org!e>ternal!default!&*$Content$erver!&*$1!%0!F4F!F7!!FF

F??=E88F4FF7F8FI=!5endered!1*!88F?F1(0F1har4F0o>?=E==0F41(0

6%C4.pdf

This book discusses the wide range of challenges faced by policymakers in the pharmaceutical

sector, presents the current know-how in terms of policy measures, and provides specific e>amples

of policy packages, even in the event of political resistance and capacity limits. This book focuses ondeveloping countries and tries to address the issues faced by both low- and middle-income

countries. Chapter ?, titled 1atterns of *ysfunction, reviews corruption and bribery in the

pharmaceutical sector.


45/96

Corruption within the pharmaceutical supply chain to the developing world !;

(itle

Access to edicines and the *ole of #orporate 8ocial *esponsibility: (he 3eed

to #raft a $lobal 5harmaceutical 8ystem )ith Integrity in (he #ambridge

(etboo4 of =ioethics

Author NC +ohler and 1 %llingworth

5ublisher Cambridge (niversity 1ress

Eear FF3

0pense 1urchase only

+*& http:!!books.google.ca!books!about!TheCambridgete>tbookofbioethics.htmlt and reference for clinicians, bioethicists and advanced students seeking a better

understanding of ethical problems in the clinical setting. The chapter on access to medicine and

corporate social responsibility by +oher and %llingworth e>amines the role C$5 plays in shaping anti-

corruption and good governance approaches to medicines access.

(itleAccess to edicines as a uman *ight: 'hat are the Implications for

5harmaceutical Industry *esponsibility

Author 6isa orman and Nillian Clare +ohler

5ublisher (niversity of Toronto 1ress

Eear F4


+*& http:!!books.google.ca!books


46/96

/


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Corruption within the pharmaceutical supply chain to the developing world /1

(itle #orporate #rime in the 5harmaceutical Industry

Author Nohn 0raithwaite

5ublisher 5outledge

Eear 4E3= F4 "nd edition)


+*& http:!!books.google.ca!booksternal!default!&*$Content$erver!%&?1!%0!F4!F7!48!FF

F?374E=F4F748F?84!5endered!1*!7EE=?F1(0F1ublF7I37E0FEI3F34?

E8?43.pdf

or decades, corruption in ;thiopia has only been discussed at the margins. 1erhaps because manyhave not e>perienced corruption as a significant constraint to their lives and businesses, or perhaps

because a culture of circumspection has dampened open dialogue, ;thiopia has neither seen the

information flows nor the debate on corruption that most other countries have seen in recent years.

This study attempts to fill this information gap. Conducted by the &orld 0ank "with financial support

from the (nited +ingdom, the etherlands and Canada) in con2unction with the ederal ;thics and

Anti-corruption Commission of ;thiopia, the study is an independent overview of corruption. The

sectors covered are health "chapter ), education, water, 2ustice, construction, land,

telecommunications and mining.


48/96


49/96

Corruption within the pharmaceutical supply chain to the developing world /!

(itle 5harmaceutical *eform: A $uide to Improving 5erformance and 0quity

Author #arc 5oberts and #ichael 5eich


Eear F44

0pense ree

+*& http:!!www-

wds.worldbank.org!e>ternal!default!&*$Content$erver!&*$1!%0!F44!FE!3!FF

F?374E=F44FE3F4?87!5endered!1*!7=777F1(0F1harFF0o>?748=?0FF1(0

6%CF.pdf

#edicines are important beyond their therapeutic utility: they are often seen by the public as the

most tangible representation of healthcare, and their availability is taken "sometimes

problematically) as an indicator of the @uality and accessibility of services. Het despite the integral

role of medicines in health system performance, the availability and appropriate use of essential

medicines in developing countries continues to be a challenge. #any countries e>perience serious

difficulties in providing high-@uality services, free of corruption in the public sector. Chapter 3

provides commentary on pharmaceutical corruption.

(itle5harmaceutical Anti-counterfeiting: #ombating the *eal %anger from a4e

%rugs

Author #ark *avison

5ublisher Nohn &iley $ons

Eear F44


+*& http:!!books.google.ca!books


50/96

// pen 0riefing

5eports

(itleA rame)or4 for $ood $overnance in the 5harmaceutical 8ector: $$ odel

rame)or4

Author ;loy Anello

5ublisher &orld 'ealth rganisation

Eear FF3

0pense ree

+*& http:!!www.who.int!medicines!areas!policy!goodgovernance!//#frameworkFE.pdf

%n an attempt to curb corruption in pharmaceutical systems, &' established the /ood /overnance

for #edicines programme. The programmePs goal is to reduce corruption in pharmaceutical systems

through the application of transparent, accountable administrative procedures and the promotion

of ethical practices. %n the //# programme, the focus is on the fundamental need to have good

laws, regulations, policies and procedures in place to improve the management of the medicines

chain and a corruption-free environment to promote access to good-@uality medicines.

(itleAddressing corruption in the health sector: 8ecuring equitable access to

healthcare for everyone

Author +aren 'ussmann

5ublisher (= Anti-Corruption 5esource Centre

Eear F44

0pense ree

+*&http:!!www.u=.no!publications!addressing-corruption-in-the-health-sector-

securing-e@uitable-access-to-health-care-for-everyone!

The development community is striving to achieve results and value for money with its investments

in health around the world. Het, donors often work in countries where the risk of corruption is high

and where public management and oversight systems are weak. The main purpose of this (= %ssue is

to increase awareness around corruption in the health sector and provide practical guidance on how

to identify and prevent it.


51/96


52/96

/7 pen 0riefing

(itleAssessment of $overnance and #orruption in the 5harmaceutical 8ector:

&essons &earned from &o) and iddle Income #ountries

Author Aissatou *iack, Andreas $eiter, 6oraine 'awkins and %mad $ubhi *weik


Eear F4F

0pense ree

+*& http:!!siteresources.worldbank.org!';A6T'(T5%T%A*11(6AT%!5esources

!347I-4FE87E34=F47I!1harm/overnance/uidanceote.pdf

1harmaceuticals are a critical input for the health sector. At the same time, the drug business

sustains many individual and corporate livelihoods and produces handsome returns for those

involved in the trade. /ood governance is critical for the sector to ma>imise returns for public health

and minimise risks for patients from ineffective or contaminated drugs. /iven the large financial

volume of the market, the potential for corruption is significant. Oulnerable points are those at

which decisions about market access and purchasing are made. This includes institutional functions

such as licensing, inclusion into formularies and public procurement as well as the individual

prescriber, who selects drugs for a specific patient.

(itle Assessment of medicines regulatory systems in sub-8aharan African countries

Author &orld 'ealth rganisation


Eear F4F

0pense ree

+*& http:!!apps.who.int!medicinedocs!documents!s4I8IIen!s4I8IIen.pdf

This report summariGes the findings of ?F assessments of regulatory systems carried out by

assessment teams on behalf of &'s *epartment of ;ssential #edicines and 1harmaceutical

1olicies. $tructures for medicines regulation e>isted in the countries assessed, and the mainregulatory functions were addressed, although in practice the measures were often inade@uate and

did not form a coherent regulatory system. Common weaknesses included a fragmented legal basis

in need of consolidation, weak management structures and processes, and a severe lack of staff and

resources. n the whole, countries did not have the capacity to control the @uality, safety and

efficacy of the medicines circulating on their markets or passing through their territories


53/96

Corruption within the pharmaceutical supply chain to the developing world /9

(itle =ribery in ealth #are in 5eru and +ganda

Author Nennifer 'unt

5ublisher ational 0ureau of ;conomic 5esearch

Eear FFI

0pense ree

+*& http:!!www.nber.org!papers!w4?F?=

This paper e>amines the role of household income in determining who bribes and how much they

bribe in healthcare in 1eru and (ganda. 5ich patients are more likely than other patients to bribe in

public healthcare: doubling household consumption increases the bribery probability by F.-F.=

percentage points in 1eru, compared to a bribery rate of F.3S doubling household e>penditure in

(ganda increases the bribery probability by 4. percentage points compared to a bribery rate of

4IS. The income elasticity of the bribe amount cannot be precisely estimated in 1eru, but is about

F.?I in (ganda. 0ribes in the (gandan public sector appear to be fees-for-service e>torted from the

richer patients amongst those e>empted by government policy from paying the official fees. 0ribes

in the private sector appear to be flat-rate fees paid by patients who do not pay official fees.

(itle#ombating #ounterfeit, alsified and 8ubstandard edicines: %efining the

'ay or)ardF

Author Charles Clift

5ublisher Chatham 'ouse Q Centre on /lobal 'ealth $ecurity

Eear F4F

0pense ree

+*& http:!!www.chathamhouse.org!publications!papers!view!4FE84I

Counterfeit, falsified and substandard medicines pose a considerable threat to health. Although

detailed knowledge of their prevalence and impact on human health is limited, they can fail to cure,

promote antimicrobial resistance, and ultimately kill. The threat from these medicines is probablygrowing, particularly in poorer countries with weak regulatory mechanisms and poorly monitored

distribution networks.

Counterfeiting can be very profitable and counterfeiters are becoming increasingly sophisticated.

This makes patients in developing countries particularly vulnerable, since they usually have to buy

medicines from their own resources.


54/96

/ pen 0riefing

(itle #orruption and health ependiture in Italy

Author 5affaele 6agravinese and #assimo 1aradiso

5ublisher #unich 1ersonal 5e1;c Archive

Eear F4

0pense ree

+*& http:!!mpra.ub.uni-muenchen.de!=?48!

The vulnerability of the health sector to corruption lies in the comple> interaction between the

social environment and the institutional setting of health systems. This interaction is investigated in

the case of %taly, specifically looking at the impact of corruption on health e>penditure. The health

sector has often been involved in corruption offences and decentralised health e>penditure is

considerably out of control.

(itle#orruption and 5harmaceuticals: 8trengthening $ood $overnance to Improve

Access

Author Nillian Clare Cohen, #oni@ue #raGek and 6oraine 'awkins


Eear FFI

0pense ree

+*& http:!!idea.phm.utoronto.ca!1*!+ohler,SFCorruptionSFandSF1harmaceutic

als.pdf

Access to safe, good @uality and affordable pharmaceuticals continues to be one of the main

problems affecting global health and corruption is one of the key driving factors. This chapter

presents an overview of the problem of corruption in the pharmaceutical sector and e@uips decision

makers with the tools to identify vulnerabilities and prioritise strategies to tackle this problem.


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Corruption within the pharmaceutical supply chain to the developing world /;

(itle #orruption in ealthcare 8ystems

Author $hu Hang 'u, Christopher Cadham, Nennifer Hu and #ari /alloway

5ublisher #on&' #ontreal

Eear F4

0pense ree

+*& http:!!www.monwho.org!wp-

content!uploads!F4?!F!#on&'SFThemeSF/uideSFF4?SFinal.pdf

Corruption is a pervasive and comple> problem in healthcare systems impacts health status and

healthcare accessibility. &hile it is impossible to determine the e>act global costs of corruption in

the health sector, it is apparent that corruption amounts to billions of dollars annually. Corruption is

often largely responsible for the absence of improved health outcomes with increased spending on

health.

(itle #orruption in *ussian ealth #are: (he %eterminants and Incidence of =ribery

Author +lara $abirianova 1eter and Tetyana Melenska

5ublisher %nstitute for the $tudy of 6abor

Eear F4F

0pense ree

+*& http:!!www.iGa.org!conferencefiles!worldbF4F!Gelenskat8?FF.pdf

This paper uses the 5ussian 6ongitudinal #onitoring $urvey to e>amine the incidence and

determinants of informal payments in 5ussian healthcare industry during 4EE=-FF8. indings

indicate that long-run endowments of healthcare sector, greater economic development and higher

healthcare e>penditure have a bribery-reducing effect, while short-run budgetary fluctuations do

not have a discernible effect on bribery. There is also a positive association between salary of

medical personnel and bribery but this effect is not robust. %nterestingly, the private sector is more

prone to corruption.


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6


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(itle $ood $overnance and ealth: Assessing 5rogress in *)anda

Author *erick &. 0rinkerhoff, Catherine ort and $ara $tratton

5ublisher ($A%* and Twubakane

Eear FFE

0pense ree

+*& http:!!www.intrahealth.org!Yintrahea!files!media!good-governance-and-

healthassessing-progress-in-rwanda!goodgovandhealth.pdf

;>perience around the world has demonstrated that attention to governance is important to the

ability of health systems to fulfil essential public health functions. 'ealth governance concerns the

institutions and linkages that affect the interactions among citiGens!service users, government

officials and health service providers. There is general agreement that good health governance is

characterised by responsiveness and accountability an open and transparent policy process

participatory engagement of citiGens and operational capacity of government to plan, manage, and

regulate policy and service delivery.

(itle $ood governance for medicines initiatives: 0ploring lessons learned

Author Nillian Clare +ohler and atalia vtcharenko


Eear F4?

0pense ree

+*& http:!!www.u=.no!publications!good-governance-for-medicines-initiatives-

e>ploring-lessons-learned!

Corruption in the pharmaceutical system results in wasted resources, limited access to health

services and reduced health gains. %n this (= %ssue paper, we e>amine select global initiatives in the

area of good governance and medicines that have been applied since FFF. These initiatives taken

by the &orld 0ank, the &' and the /lobal und, as well as the #edicines Transparency Alliance,have been particularly useful in generating a political and policy dialogue around the issue of

pharmaceutical system good governance.


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62 pen 0riefing

(itle $overning for =etter ealth: A (argeted &iterature *evie)

Authors # $hukla and + Nohnson 6assner

5ublisher ($ Agency for %nternational *evelopment

Eear F4

0pense ree

+*& http:!!www4.msh.org!global-presence!upload!?-/overnance-

%nterviews#ayF4%A615%Tupdated.pdf

This literature review, carried out by the ($A%* 6eadership, #anagement, and /overnance pro2ect,

was conducted to help identify key concepts and practices that inform the development and use of

technical assistance and leadership development training of those who govern in the health sectors

of low and middle-income countries.

(itle ealth 8ector $overnance and Implications for the 5rivate 8ector

Author *ina 0alabanova, Oaleria liveira-CruG and +ara 'anson

5ublisher 5ockefeller oundation

Eear FF3

0pense ree

+*& http:!!www.resultsfordevelopment.org!sites!resultsfordevelopment.org!files!resou

rces!'ealthSF$ectorSF/overnanceSFandSF%mplicationsSFforSFtheSF1r

ivateSF$ector.pdf

The private sector plays an increasingly important role in the health systems of low- and middle-

income countries. $caling up the delivery of essential interventions to achieve international health

targets is dependent on working with it. The private health sector includes an enormous diversity of

actors, including providers, funder, and suppliers of physical and knowledge inputs for the health

sector. The boundaries between the public and private sectors are often unclear as many private

actors operate outside the regulatory framework of the health sector on an informal basis.


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(itle Informal 5ayments and oonlighting in (a@i4istan’s ealth 8ector

Author Andrew *abalen and &aly &ane


Eear FF3

0pense ree

+*& http:!!elibrary.worldbank.org!docserver!download!=888.pdfpiresB4?7EE3I84

idBidaccnameBguestchecksumBI3*F7I*7=A8A7?I=FI*I?7==3;3A

This paper studies the relationship between gender and corruption in the health sector. %t uses data

collected directly from health workers, during a recent public e>penditure tracking survey in

Ta2ikistans health sector. The paper provides evidence that workers are more likely to engage in

informal charging the farther they fall short of their perceived fair-wage, adding weight to the fair

wage-corruption hypothesis. inally, there is some evidence that health workers who feel that

healthcare should be provided for a fee are more likely to informally charge patients.

(itleeasuring (ransparency in the 5ublic 5harmaceutical 8ector: Assessment

Instrument

Author /uitelle 0aghdadi‐$abeti, Nillian Clare Cohen‐+ohler and ;shetu

&ondemagegnehu


Eear FFE

0pense ree

+*& http:!!www.who.int!medicines!areas!policy!goodgovernance!Assessment%nstrum

ent#eastransp;/.1*

A number of factors contribute to the urgent challenges in the pharmaceutical sector, including

poverty, market failures and government failures. The latter often results, at least in part, from a

lack of transparency in the pharmaceutical system. 6ack of transparency in the pharmaceuticalsystem is an issue of increasing concern because bad practices can waste resources, which in turn

reduces the availability of essential medicines and so threatens the well‐being of populations.


60/96

6/ pen 0riefing

(itle oDambique: #orruption undermining health service

Author -

5ublisher %ntegrated 5egional %nformation etwork

Eear F4

0pense ree

+*& http:!!www.refworld.org!docid!8Fbdd37.html

Corruption is rife in #oGambi@uePs public health sector. According to a FF7 study by the Centre for

1ublic %ntegrity in #aputo, corruption is present at all levels in the system: from the reception to the

laboratory, during appointments with doctors, and even at the morgue. A F44 regional household

survey by Transparency %nternational found that nearly =FS of #oGambican respondents had paid

bribes for medical services in the past year Q the highest such figure in the region. %n #oGambi@ue, it

was second only to the percentage that had paid bribes to the police.

(itle 5a4istan’s health sector: %oes corruption lur4F

Author 'eartfile

5ublisher 'eartfile

Eear FF3

0pense ree

+*& http:!!www.heartfile.org!pdf!health-sector-corruption-pakistan.pdf

This paper constitutes the preamble for the first chapter of a monograph for the 1artnership for

Transparency und, &1 'ealth 5eform (nit and 'eartfiles collaborative study Assessing

governance for eliminating corruption in the health sector in 1akistan.


61/96


(itle5harmaceutical Access in &east %eveloped #ountries: "n-the-ground barriers

and industry successes

Author * &ayne Taylor

5ublisher Cameron %nstitute

Eear F4F

0pense ree

+*&

http:!!cameroninstitute.com!inde>.phpistent health human

resources and infrastructure, and the lack of both local and international political will.

(itle 5olitical 0conomy Analysis of the ealth 8ector *ural ealth 8ervices in $hana

Author 1atrick Apoya

5ublisher $TA5-/hana

Eear F4

0pense ree

+*& http:!!www.starghana.org!assets!1;SFAnalysisSFofSF'ealthSF5eport.pdf

This analysis addresses three key tasks. The first is an analysis of the political economy of the health

sector, particularly as it relates to the government business cycle and with emphasis on rural health

services. %n particular, the analysis identified where the drivers of change within the sector "issues,

institutions, actors, etc) are located and assess previous initiatives to promote accountability and

responsiveness in the delivery of health services, particularly for rural parts of the country and for

e>cluded social groups. The second task is drawing out the implications of this analysis for

development of programme strategy, specifically strategies for promoting coalitions and alliancesbetween and amongst key actors at national, district and local levels to address the issues of

concern to the actors. The third task is identification of key issues affecting pro-poor service delivery

and access, drivers of change and opportunities for facilitating diverse alliances of stakeholders to

enable the poor access @uality services.


62/96

67 pen 0riefing

(itle *ighting the $lobal und

Author N. $tephen #orrison and Todd $ummers

5ublisher Center for $trategic and %nternational $tudies

Eear F4

0pense ree

+*& http:!!csis.org!files!publication!4FI#orrison5ighting/lobalund&eb.pdf

ver the course of F44, the /eneva-based /lobal und to ight Aids, Tuberculosis, and #alaria

e>perienced unprecedented adversity. #edia accounts and internal reports drew attention to

instances of corruption involving grantees: V?= million of probable fraud in four African countries

triggered a suspension of assistance by /ermany and two other ;uropean donors. ;>ternal reviews

detailed the unds deficient managerial practices, weak oversight of investments and ineffectual

board governance.

(itle8trengthening pharmaceutical systems through transparency and accountability:

the e(A ?yrgyDstan frame)or4

Author *2anyl *2usupova and #ariam *2ankoroGova

5ublisher #edicines Transparency Alliance

Eear FFE

0pense ree

+*& http:!!www.medicinestransparency.org!fileadmin!uploads!*ocuments!+yrgyGstan-

#eTA-&orkplan.pdf

ollowing initial e>pression of interest from the #inistry of 'ealth and the #andatory 'ealth

%nsurance und, a scoping visit to e>plore potential for a #eTA pilot in +yrgyGstan was carried out on

-7 Nuly FFI. The current #inister of 'ealth "#') granted official approval for +yrgyGstan to

participate in #eTA as a pilot country: he e>pressed particular concern about high medicine prices

and affordability of medicines. 'e noted that despite removal of Oalue Added Ta> on medicines,prices did not change and competition decreased. 'e also e>pressed concern about limited physical

access to medicines in rural areas.


63/96


64/96

6 pen 0riefing

(itle(ransparency and accountability in an electronic era: the case of

pharmaceutical procurements

Author 0renda &aning and Taryn Oian


Eear FF3

0pense ree

+*& http:!!www.u=.no!publications!transparency-and-accountability-in-an-electronic-

era-the-case-of-pharmaceutical-procurements!

The burgeoning '%O!Aids epidemic means that more labour and financial resources are being

dedicated to the procurement of antiretroviral medicines for treatment. &hile patients, physicians,

national governments and development partners are eager to see treatment programmes

e>panded, rapid scale up often results in circumstances whereby resources have to be spent @uickly,

and sometimes resources are added to systems that are already weak and vulnerable to corruption.

This (= 0rief describes how international partners and national procurement agencies have used

information technology to improve transparency and increase accountability in procurement of

'%O!Aids medicines.

(itle (ransparency %eficit: A *eport on IGBAids unding in 3igeria

Authors 0abatunde lugbo2i, Adede2i Adeleye and $egun akorede

5ublisher %ndependent Advocacy 1ro2ect

Eear FFE

0pense ree

+*& http:!!www.km=h.com!dataSFforSFkm=h!0ooks!transparencySFdeflict.pdf

ver a one year period, %ndependent Advocacy 1ro2ect conducted a study on the management and

allocation of '%O!Aids funding in igeria as a constituent of the programme 1romoting

Accountability and Transparency in '%O!Aids funding "1AT'). The outcome of this study is thisreport, which scrutinised '%O!Aids funding and related issues, the performance of the ational

Agency for the Control of Aids and the $tate Action Committee on Aids against the background of

corruption in the countrys health sector.


65/96


(itleGulnerabilities to corruption in the ealth 8ector: 5erspectives from &atin

America 8ub-systems for the 5oor

Author +aren 'ussmann

5ublisher ( *evelopment 1rogramme

Eear F44

0pense ree

+*& http:!!www.u=.no!recommended-reading!vulnerabilities-to-corruption-in-the-

health-sector-perspectives-from-latin-american-sub-systems-for-the-poor-with-a-

special-focus-on-the-sub-national-level!

Transparency and accountability are widely recognised as crucial dimensions of democratic

governance. %n the health sector democratic governance is acknowledged as one of the key building

blocks for health systems strengthening as laid out by the &orld 'ealth rganisation. Het, in 6atin

America and the Caribbean there is little knowledge and awareness about an important cause and

conse@uence of bad governance in health systems: corruption.

(itle'atching Eour ealth: apping (ransparency and Integrity *is4s in ealth

8ervice %elivery in Africa

Authors 1aul 0ukuluki, Nohn $sengendo, *avid #afigiri, 1eter 0yansi and 1aul 0anoba

5ublisher Transparency %nternational Q (ganda

Eear F44

0pense ree

+*& http:!!www.transparency.org!news!pressrelease!F4444=ugandatisda

This report presents the findings of an assessment of transparency and integrity in the health sector

in (ganda. The study adopted the approach of the 'ealth $ystems ramework, which identifies si>

building blocks of health systems namely: health financing, health leadership and governance,

medical products and technologies, health information, health workforce and health servicedelivery. The study investigated issues of governance, namely transparency, accountability, integrity,

public participation, corruption and institutional performance in each of the building blocks.


66/96

7 and multi-faceted challenge, &' launched

the /ood /overnance for #edicines programme in FF=. %nitially a pilot pro2ect in four Asian

countries, the //# grew rapidly to become a global programme implemented in 7 countries. This

paper is intended to share country e>periences in implementing the //# programme in the last si>

years. %t is based on information received from countries that have already implemented the //#

and have documented their e>periences. This paper also offers a number of analyses on best

practices and lessons learnt.


67/96


Nournal Articles

(itle An eamination of pharmaceutical systems in severely disrupted countries

Author Nillian Clare +ohler, ;nrico 1avignani, #arkus #ichael, atalia vtcharenko,

#auriGio #urru and 1eter $ 'ill

5ublisher 0#C %nternational 'ealth and 'uman 5ights

Eear F4

0pense ree

+*& http:!!www.biomedcentral.com!4=I-7E3R!4!?=

This research assesses informal markets that dominate pharmaceutical systems in severely

disrupted countries and identifies areas for further investigation. indings are based on recent

academic papers, policy and grey literature, and field studies in $omalia, Afghanistan, the

*emocratic 5epublic of Congo and 'aiti. The public sector in the studied countries is characterised

in part by weak #inistries of 'ealth and low donor coordination. %nformal markets, where medicines

are regularly sold in market stalls and unregulated pharmacies, often accompanied by un@ualified

medical advice, have proliferated. Counterfeit and sub-standard medicines trade networks have also

developed. To help increase medicine availability for citiGens, informal markets should be integrated

into e>isting access to medicines initiatives.

(itle =enchmar4ing and (ransparency: Incentives for the 5harmaceutical Industry’s#orporate 8ocial *esponsibility

Author #atthew 6ee and Nillian +ohler

5ublisher Nournal of 0usiness ;thics

Eear F4F


+*& http:!!link.springer.com!article!4F.4FFISs4F884-F4F-F===-y

&ith over two billion people lacking medicines for treatable diseases and 4= million people dying

annually from infectious disease, there is undeniable need for increased access to medicines. There

has been an increasing trend to benchmark the pharmaceutical industry on their corporate social

responsibility performance in access to medicines. 0enchmarking creates a competitive inter-

business environment and acts as incentive for improving C$5. This article investigates the

corporate feedback discourses pharmaceutical companies make in response to criticisms from

benchmarking reports.


68/96

72 pen 0riefing

(itle#ombating healthcare corruption and fraud )ith improved global health

governance

Author Tim + #ackey and 0ryan A 6iang

5ublisher 0#C %nternational 'ealth and 'uman 5ights

Eear F4

0pense ree

+*& http:!!www.biomedcentral.com!4=I-7E3R!4!?

Corruption is a serious threat to global health outcomes, leading to financial waste and adverse

health conse@uences. Het, forms of corruption impacting global health are endemic worldwide in

public and private sectors, and in developed and resource-poor settings alike. Allegations of misuse

of funds and fraud in global health initiatives also threaten future investment. Current domestic and

sectoral-level responses are fragmented and have been criticised as ineffective. %n order to address

this issue, we propose a global health governance framework calling for international recognition of

global health corruption and development of a treaty protocol to combat this crucial issue.

(itle#onflicts of Interest, Institutional #orruption, and 5harma:

corruption-within-the-pharmaceutical-supply-chain.pdf

Documents