GlaxoSmithKline PLC’s record-breaking $3 billion settlement with the Department of Justice is remarkable in its breadth – including guilty pleas for promoting drugs off-label and hiding safety data from FDA and allegations of kickbacks involving nine products. But it also imposes novel penalties on executives through an accompanying corporate integrity agreement (CIA).
The CIA, which GSK entered into with HHS’ Office of Inspector General, requires the company to recoup annual bonuses and incentives from executives if they or their subordinates engage in “significant misconduct