NUESTRA COMPAÑÍA: Pan Am Farma ANTI-FRAUD COMPLIANCE PROGRAMME
Pan Am Farma 1. Introduction
Distribuidora Farmacéutico Pan Americana SA de CV (Panamfarma) is committed to maintaining the highest ethical standards and preventing fraud in all aspects of our pharmaceutical distribution and export operations. Fraudulent activities pose a significant risk to patient safety, business integrity, and regulatory compliance.
This Anti-Fraud Compliance Programme establishes policies, procedures, and controls to prevent, detect, and respond to fraudulent activities, ensuring compliance with Mexican, international, and pharmaceutical industry regulations.
Pan Am Farma OBJECTIVES
2. Objectives of the Programme
The primary objectives of Panamfarma’s Anti-Fraud Compliance Programme are:
- Preventing and detecting fraud within the organization and supply chain.
- Ensuring compliance with COFEPRIS, WHO, FDA, EMA, and other regulatory bodies.
- Protecting patients, stakeholders, and financial integrity by enforcing strict anti-fraud controls.
- Encouraging transparency, accountability, and ethical business practices.
- Establishing procedures for whistleblowing and fraud investigation.
3. Definition of Fraud
Fraud is defined as any deliberate act of deception, dishonesty, or misrepresentation intended to secure an unlawful financial or business advantage. Examples of fraud in the pharmaceutical sector include:
- Product fraud– Counterfeit, substandard, or misrepresented pharmaceuticals.
- Financial fraud– Embezzlement, invoice manipulation, price-fixing, or false reporting.
- Procurement fraud– Bribery, bid-rigging, or undisclosed conflicts of interest.
- Regulatory fraud– False documentation, mislabeling, or non-compliance with licensing requirements.
- Corruption & bribery– Unlawful payments to government officials or healthcare providers.
- Supply chain fraud– Diversion, smuggling, or unauthorized distribution of pharmaceuticals.
4. Fraud Prevention Measures
Panamfarma has implemented comprehensive fraud prevention measures to safeguard our pharmaceutical distribution and export operations.
4.1 Internal Controls & Risk Assessments
- Regular audits and financial controls to detect irregularities.
- Strict segregation of duties in procurement, financial transactions, and regulatory compliance.
- Supply chain traceability and verification to prevent counterfeit drug infiltration.
- Advanced tracking systems for pharmaceutical shipments and warehouse inventory.
4.2 Compliance with Anti-Corruption Laws
- Full adherence to Mexico’s Anti-Corruption Law (Ley General de Responsabilidades Administrativas).
- Compliance with the U.S. Foreign Corrupt Practices Act (FCPA)and UK Bribery Act in international dealings.
- Strict due diligence for third-party suppliers and business partners.
- Mandatory disclosure of any gifts, payments, or incentives given to public officials.
4.3 Employee & Supplier Training
- Mandatory anti-fraud training for all employees, executives, and third-party vendors.
- Code of Conduct certifications for employees and supply chain partners.
- Regular workshops on ethical business practices and regulatory compliance.
5. Fraud Detection & Reporting Mechanisms
Panamfarma has established robust mechanisms for detecting and reporting fraudulent activities.
5.1 Whistleblower Policy & Confidential Reporting
- Anonymous reporting hotline:+52 322 308 0021
- Dedicated compliance email:compliance@panamfarma.com
- Secure online reporting portal:panamfarma.com/whistleblower
- Zero tolerance for retaliation against whistleblowers acting in good faith.
5.2 Audit & Investigation Procedures
- Internal fraud monitoring team responsible for risk assessment and reporting.
- Unannounced audits of high-risk areas (procurement, distribution, financial transactions).
- Collaboration with external auditors and law enforcement for high-profile fraud investigations.
5.3 Supply Chain Monitoring & Compliance Checks
- Batch verification & serialization systems to track pharmaceuticals from origin to destination.
- Third-party supplier screening to prevent counterfeit and unethical sourcing.
- Surprise inspections of manufacturing, storage, and shipping facilities.
6. Fraud Response & Disciplinary Actions
6.1 Immediate Response to Fraud Incidents
Upon detection of fraud, Panamfarma will take the following steps:
- Immediate suspension of fraudulent transactions or personnel.
- Internal investigation led by the Compliance & Risk Management team.
- Reporting to regulatory authorities(COFEPRIS, WHO, FDA, or local enforcement).
- Legal action and recovery of financial losses, if applicable.
6.2 Disciplinary Measures
Fraudulent activities will result in:
- Immediate termination of employees or suppliers involved in fraud.
- Legal prosecution under applicable anti-fraud laws.
- Permanent blacklisting from Panamfarma’s supplier and partner network.
- Financial restitution or fines, depending on the severity of the fraud.
7. Commitment to Continuous Compliance
Panamfarma is committed to continuous improvement of its anti-fraud compliance measures through:
- Annual fraud risk assessments and updates to fraud prevention policies.
- Regular training and awareness programs for employees and partners.
- Strengthening partnerships with regulatory agencies to combat pharmaceutical fraud.
- Implementation of emerging technologies (AI-driven monitoring, blockchain for supply chain integrity).
8. Conclusion & Signatory Authority
This Anti-Fraud Compliance Programme reflects Panamfarma’s commitment to ethical pharmaceutical distribution, regulatory compliance, and financial integrity. We expect full adherence from all employees, suppliers, and business partners.
