Our rigorous, industry-leading compliance platform provides clients and Advisors peace of mind.
Compliance is at the heart of our services. This overview outlines some key aspects of our Compliance program. It is by no means exhaustive, but is meant to illustrate our methodology and capabilities. We recognize that each of our clients has unique needs and so we have built a flexible platform that permits clients to add custom compliance controls.
It is helpful to think of our approach in three stages:
- Advisor Eligibility
- Project Compliance
- Project Review
Conservative Rules: Aathena has implemented conservative rules to which every Advisor must agree before a consultation may take place. These rules are designed to provide our Advisors with clear boundaries and they directly address sensitive subjects such as clinical trials, employers, and competitors. You may review a Summary of Key Rules or our Terms and Conditions for greater detail.
Instruction: We instruct our Advisors about compliance through several tools, including an interactive Advisor Compliance Tutorial that explains our Advisors’ obligations and provides a series of questions that require our Advisors to apply our rules to different fact patterns. Advisors must affirm that they have completed the tutorial upon joining our network and must represent prior to each consultation that they have reviewed the Advisor Compliance Tutorial within the 12 months prior to the consultation. Additional training tools include answers to our Frequently Asked Questions.
Background Checks: We run periodic background checks through a global risk intelligence service on all new Advisors and a substantial sampling of Advisors who have performed consultations through us. This check encompasses, among other things, criminal histories in the U.S. and foreign jurisdictions, as well as U.S. FDA debarment actions and the GSA’s Excluded Parties List System.
Employer Opt-Out: Aathena will not accept as Advisors the employees of a company, or its subsidiaries, that Aathenat believes bars its employees from participating in the network. To support this policy, when Aathena learns of any such prohibition, it records the company in the Aathena Employer Database Registry. This registry list automated into Aathena’s IT platform to ensure Advisors identified in our database as employees of companies on the list are not permitted to participate in consultations.
Corporate Data Feed: Aathena uses a third-party corporate information service that feeds data, including companies’ affiliates, into our IT platform to help us apply compliance restrictions.
Project Manager Screen: At the commencement of each project, a Project Manager reviews the request to determine whether the experts and information sought comply with Aathena’s rules. Project Managers may request additional information from clients and enlist Aathena’s Legal and Compliance Departments, as needed.
Client Customized Screens: A client may request that additional custom controls be applied to their projects. Such controls may include tailored compliance screening questions, client approval of experts chose or required Advisor affirmations.
Compliance Reconfirmation for Every Project: Advisors must affirm in advance of each project that they will conduct that consultation in conformity with the Terms and Conditions.
Automation of Our Compliance Controls: Our proprietary IT platform will not permit Project Managers to move to the next step in the project workflow until they have completed all compliance screens and obtained any necessary client compliance approvals.
Advisors Paid for Compliance: Our Advisors are obligated to terminate any consultation in which they believe they are being solicited to violate our compliance rules. If they terminate early for this reason, we still pay them for the full consultation.
Systematic Review and Follow-up: We employ a team of full-time compliance professionals. This team reviews a sampling of projects at different stages, searching for issues that bear further examination. Where appropriate, they follow-up with additional inquiry. Advisors who violate our rules can –and have been – removed from our service
Record Keeping: We have made a substantial invesment in a proprietary IT platform that enables review of projects at all stages, and provides a complete audit trail of requests and consultations.
Client Project Interface: Our client interface allows client compliance personnel to monitor usage and project details in real-time and download consultation information as required.