In this renewed era of individual responsibility for corporate malfeasance, corporate counsel would be well advised to help protect themselves from personal liability by taking six steps of their own when notified of allegations of wrongdoing within the company.
Five years ago, the U.S. Justice Department announced that it had charged GlaxoSmithKline Vice President and Associate General Counsel Lauren Stevens with two counts of obstruction of justice and four counts of making false statements to the Food and Drug Administration (FDA). At issue were allegations that Stevens had sent a series of letters to the FDA denying that the company had promoted its drug Wellbutrin for off-label uses and that she failed to turn over evidence to the contrary, including various slides used by physicians paid by the company to promote the drug’s off-label use.
Continue Reading Part 1: The Changing Corporate Counsel Landscape