Global Thinking

For much of his 11-plus years as executive vice president and general counsel at Perrigo Company, Todd Kingma has been working to formalize the company’s compliance program. ‘We had a decent compliance program 10 years ago, but through many, many skilled colleagues we have developed an ever-improved program and today we have a very robust compliance program that I’m very proud of,’ he says.

With the recent acquisition of European over-the-counter drug manufacturer Omega Pharma, Perrigo expects its revenue from outside the US to soon jump to 45 percent from its current 20 percent. Chairman and chief executive Joseph Papa recently said his goal is to have one third of the company’s revenue generated from the US, one third from Europe and one third from Asia. That expanding business footprint outside the US brings additional compliance challenges, such as training employees based in non-US territories who may have different cultural approaches to compliance and ethics.

‘We’re in high-risk countries – yes, we’re very active in that regard,’ Kingma says. ‘Just making sure that people think about this on a daily basis is a great challenge but, to the credit of my colleagues, they keep [compliance] at the forefront.’

Perrigo’s compliance department provides pretty extensive training, some of it in person and much of it through online modules. One of the biggest challenges Kingma has noticed is the ever-present risk that employees could begin to take the company’s compliance culture for granted. That’s one reason he and other members of the legal team make a point of traveling the world to various Perrigo locations to offer guidance, in addition to having in place local site-level co-ordinators to address employees’ compliance questions and concerns.

‘You can get a lot done online, but you can never beat in-person [training],’ Kingma points out. ‘That’s a hard thing when you have a global company – to get around the world and talk to everybody – but we try to make an effort at least once a year to make sure we visit every location around the world and provide in-person training.’

As Kingma pointed out in an interview in Profile last summer, Perrigo hasn’t had any material compliance issues such as significant fines or recalls; nor has it had to close an operation in order to address quality deficiencies, as some competitors have.

‘Probably the biggest thing we work on is to prevent what I call a slow fade of compliance, where [we start thinking], We’re a good company, we don’t do these things, so we let things go, cut corners – I never want that to happen,’ says Kingma. ‘We try to keep compliance first and foremost. Our CEO mentions it on a regular basis.

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