By Randy Stpehens and Mary Bennett
Smart device manufacturers implement compliance programs to minimize the risk of corruption through policies, hotlines, training and auditing. However, such controls are largely aimed at shaping the behavior of their employees. What about agents, distributors and other third party partners? After all, the GlaxoSmithKline corruption scandal allegedly involved the use of travel agencies1. What about third parties acting on their own, yet on behalf of a medical device firm?