Chapter 4: Evaluation Processes, Investigations, and Noncompliance Response

Resource: Sample Upjohn Warning

By Virginia MacSuibhne and Meric Craig Bloch

I am a lawyer for or from [Corporation A]. I represent only [Corporation A]. I do not represent you personally.

I am conducting this interview to gather facts in order to provide legal advice to [Corporation A]. This interview is part of an investigation to determine the facts and circumstances of [X] in order to advise [Corporation A] how best to proceed.

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About SCCE

The Society of Corporate Compliance and Ethics (SCCE) is a non-profit, member-based professional association. SCCE supports our members' work with education, news, and discussion forums. We are a community of leaders, defining and shaping the corporate compliance environment across a wide range of industries and geographic regions. In developing and maintaining effective ethics and compliance programs, our members strengthen and protect their companies.

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About HCCA

The Health Care Compliance Association (HCCA), is a 501(c)6 non-profit, member-based professional association. HCCA was established in 1996 and is headquartered in Minneapolis, MN. We provide training, certification, and other resources to over 10,000 members. Our members include compliance officers and staff from a wide range of organizations, including hospitals, research facilities, clinics and technology service providers.

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