Talking about ethics and compliance as industry understands it within the frame of a course of Health Systems Management given at the Public Health School of the Université Libre de Bruxelles (ULB) presented itself as a challenge. On the one hand, Eucomed is putting a lot of efforts into promoting a culture of integrity and ethical business practices across the medical technology industry, but how to explain Eucomed’s compliance activities to students, mainly physicians, coming from developing countries and having so far taken a more public health approach?
In order to make the lecture interesting for the attendees, I figured that the scope of the presentation had to be wider than just the relationship between the industry and the Healthcare Professionals – which is the focus on Eucomed’s ethical guidelines and activities – and therefore focused the discussion on corruption in the healthcare system at large and the push that we see in Europe and the US to transparency, accountability and ethical governance.
I tried to contextualise ethics and compliance as industry understands it and put it in a broader perspective. Indeed there are many stakeholders in the healthcare system and the potential for abuse and corruption exists in each one of the relationships.
What I tried to illustrate by this chart is that the list of possible abuses by the different stakeholders is very long. There are informal payments, theft, illegal referral arrangements, inducement of unnecessary medical procedures, bribery of inspectors to overlook compliance, identity fraud (by the patients), abuses in the procurement of supplies by the providers (e.g. hospitals, health facilities) such as the overpayment of goods and services or substitution of lower-quality products (by suppliers).
There are several consequences linked to corruption, on the economy at large, on businesses, on the healthcare system – it is estimated that 10-25% of the global spending on public health is lost through corruption – on the population health status, and on the trust in public institutions. Therefore governments and international organisations have been trying to propose policy initiatives to re-build the trust and change behaviour (e.g. WHO Good Governance for Medicines Program, national anti-corruption regulations, increasing salary of healthcare workers). It is however to be discussed how successful these initiatives have been, a question which could be linked to the issue of ethnocentricity, i.e. do concepts such as corruption and bribery vary across cultures and societies? Are there actions that defy explanation as being culturally acceptable, medically necessary or unintentional?
This lead me to explain what industry is doing as one of the many possible initiatives, why codes of ethics and enforcement of such codes could be at least part of the solution, as long as there is a systemic approach and a collaboration between the different stakeholders. And then the question: “If Eucomed only has a European scope, who takes responsibility for the behaviour of industry in Africa?”
There is certainly a role for industry to play in Africa, but what struck me by the discussions is how more fundamental the issue of corruption is in some of the African countries, where corruption is deeply entrenched in the political culture. It appears to be the only survival strategy. So what to do about it?
– Aline Lautenberg, Legal Counsel Eucomed