According to the Cease-and-Desist Order, from at least 2009 to 2013, certain employees and agents of the company's subsidiaries conducting business in China engaged in transactions and provided things of value to foreign officials, principally healthcare professionals ("HCPs"). These payments took varied forms and were intended to influence the HCPs and thereby increase sales of the company's pharmaceutical products. Employees and managers in the involved subsidiaries attempted to conceal the true nature of the transactions through the use of complicit third parties and by improperly recording the relevant transactions on the books and records of the respective subsidiaries, which were consolidated in the financial reports of Novartis. Examples include improperly recording the payments as legitimate expenses for travel and entertainment, conferences, lecture fees, marketing events, educational seminars, and medical studies. The company also failed to devise and maintain an effective system of internal accounting controls or an effective anti-corruption compliance program.
To read or download a copy of the Cease-and-Desist order please follow this link: $25M to Settle SEC Bribery Case