Six steps to building a strong ethics and compliance programme

At the same time, investors, employ­ees and cus­tomers are now look­ing beyond tra­di­tion­al mea­sures of cor­po­rate suc­cess, plac­ing increased empha­sis on issues of sus­tain­abil­i­ty, ethics and social respon­si­bil­i­ty.

As glob­al enforce­ment of reg­u­la­tions increas­es, puni­tive fines con­tin­ue to swell and pub­lic demand for eth­i­cal busi­ness grows, the ques­tion of whether to devel­op an inte­grat­ed ethics and com­pli­ance pro­gramme is an easy one to answer.

In short, it’s not a ques­tion; it’s an imper­a­tive strate­gic deci­sion that offers numer­ous ben­e­fits: a bet­ter rep­u­ta­tion, greater trans­paren­cy, a stronger legal defence, more robust process­es and bet­ter use of data, for starters.

Yet we are nav­i­gat­ing strange and chal­leng­ing times, and imple­ment­ing an ethics and com­pli­ance pro­gramme can be an intim­i­dat­ing, if not over­whelm­ing, expe­ri­ence — espe­cial­ly if start­ing from scratch.

“The coro­n­avirus pan­dem­ic has helped to build a strong case for com­pli­ance and ethics,” says Vera Cherepano­va, ethics and com­pli­ance con­sul­tant at Stu­dio Eti­ca and the lead author of NAVEX Global’s Defin­i­tive Guide to Ethics and Com­pli­ance. “Our well­be­ing, and the well­be­ing of oth­ers, depends on how com­pli­ant we all are. In the same way, the well­be­ing of organ­i­sa­tions depends on our indi­vid­ual and col­lec­tive con­duct.”

Ahead of the launch of the new guide, which will help organ­i­sa­tions devel­op and imple­ment their own ethics and com­pli­ance pro­gramme, here are the six key steps to con­sid­er as you pur­sue your own plan.

How telemedicine can help

Telemed­i­cine has been hailed as a solu­tion. Skin diag­no­sis and mon­i­tor­ing apps, such as Skin Ana­lyt­ics, Miiskin or Mol­e­Care, present an oppor­tu­ni­ty to clear the back­log of patients cre­at­ed by the pan­dem­ic and could make it pos­si­ble to catch addi­tion­al skin can­cers ear­ly on.

Neil Daly, chief exec­u­tive of Skin Ana­lyt­ics, believes there is “no answer that doesn’t involve tech­nol­o­gy like ours”. He says: “We just don’t have the resources to cope with the num­ber of patients oth­er­wise.”

The rise in com­mer­cial skin diag­no­sis apps could reflect an increased desire for patients to take health­care into their own hands, espe­cial­ly in light of COVID-19. “It’s empow­er­ing for the patient because it enables them to take con­trol of their own health,” says Dr Sharon Wong, der­ma­tol­o­gist based at Lon­don Bridge Hos­pi­tal.

How­ev­er, there are con­cerns about unreg­u­lat­ed com­mer­cial apps diag­nos­ing and treat­ing skin can­cers and skin con­di­tions.

As der­ma­tol­o­gists we will and we should move along with how tech­nol­o­gy devel­ops. AI will be the way for­ward and we do need to adapt our ways accord­ing­ly

John Loder, invest­ment direc­tor for Nes­ta, an inno­va­tion foun­da­tion, is opti­mistic about the poten­tial of sophis­ti­cat­ed telemed­i­cine tech­nol­o­gy, but says it must be prop­er­ly reg­u­lat­ed and test­ed in clin­i­cal set­tings. “The reg­u­la­to­ry envi­ron­ment is not com­plete­ly nailed down,” he says.

A BMJ report released in Feb­ru­ary looked into pub­licly avail­able skin­Scan and Skin­Vi­sion apps, and con­clud­ed algo­rithm-based smart­phone apps had a “poor and vari­able per­for­mance”, say­ing “these apps have not yet shown suf­fi­cient promise to rec­om­mend their use”.

Challenges with app-based healthcare services

If telemed­i­cine solu­tions don’t have a high degree of accu­ra­cy they could cause addi­tion­al prob­lems, such as miss­ing can­cers and offer­ing false reas­sur­ance or fur­ther over­load­ing health­care pro­fes­sion­als.

“If a patient goes to a GP and says this app says this, it’ll be dif­fi­cult for the GP, who is not a skin expert, to dis­agree. So we could get more patients referred to the der­ma­tol­o­gist, which could even increase the work­load,” says Dr Adil Sher­az, con­sul­tant der­ma­tol­o­gist and British Skin Foun­da­tion spokesman.

On top of this, images patients take them­selves on smart­phones might not be clear, so apps could miss prob­lems.

Anoth­er con­cern is that a lot of the images in app data­bas­es are from lighter skin types. “So they could widen the gap we already have in pick­ing up melanomas in dark­er skin types,” says Sher­az. “We have to be care­ful to cater for all dif­fer­ent types of skin can­cers.”

Where it’s used, telemed­i­cine works best along­side health­care pro­fes­sion­als. One rea­son for this is the emo­tion­al ele­ment of diag­nos­ing can­cer and need to reas­sure patients, says Daly at Skin Ana­lyt­ics. “Peo­ple are real­ly com­plex and AI is a blunt tool that you need to tar­get in the right way,” he says.

For exam­ple, Wong says if a patient of hers had a lesion that looked con­cern­ing, she could prime them for the pos­si­bil­i­ty of bad news ear­ly on.

Der­ma­tol­o­gists can also exam­ine patients phys­i­cal­ly. “Ulti­mate­ly humans will pre­fer to have human inter­ac­tion and AI isn’t able to engage in that high­er-lev­el con­ver­sa­tion,” she says. “As a human we can exam­ine not just on a visu­al aspect, but also on a tac­tile aspect. We can touch the skin.”

Health services of the future

Despite the mis­giv­ings, many in pub­lic health­care and dig­i­tal health are excit­ed about the pos­si­bil­i­ty of telemed­i­cine and envi­sion a future where skin diag­no­sis apps work along­side clin­i­cians.

Dig­i­tal solu­tions can reach remote loca­tions and peo­ple unable to access ser­vices due to the coro­n­avirus pan­dem­ic. Both Wong and Sher­az say they believe skin mon­i­tor­ing apps, such as Miiskin, are already help­ful and would like to work with more reg­u­lat­ed, sophis­ti­cat­ed dig­i­tal tools in the future.

“As der­ma­tol­o­gists we will and we should move along with how tech­nol­o­gy devel­ops. AI will be the way for­ward and we do need to adapt our ways accord­ing­ly,” says Sher­az. “I’m real­ly hap­py peo­ple are look­ing at this tech­nol­o­gy.”

Wong agrees. “Dur­ing COVID we’ve used tele­d­er­ma­tol­ogy a lot and it’s only pushed to the fore­front the impor­tance of embrac­ing and work­ing along­side tech­nol­o­gy to improve patient care,” she says.

Telemed­i­cine has the poten­tial to stream­line health­care ser­vices and help der­ma­tol­o­gists to detect skin can­cers. But there are still a num­ber of chal­lenges that must be over­come to ensure the range of skin diag­no­sis apps are reg­u­lat­ed, sophis­ti­cat­ed and safe to use.

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