Eunomia designs and runs risk-based compliance monitoring for pharmaceutical and biotech companies in the UK. We monitor HCP engagements, meetings and hospitality, materials, grants and payments against the ABPI Code, anti-bribery expectations and your own procedures, and report findings and trends so issues are fixed before they become audit findings.
Discuss this service
UK expertise · Practical delivery
For compliance leaders in pharmaceutical and biotech companies in the UK who need assurance between audits: a first monitoring programme for a growing company, extra capacity for an existing plan, or a refresh after new risks or a Code ruling.
Policies, approvals and training are in place, but nobody checks whether meetings, payments and materials follow them until an audit, a complaint or a PMCPA case. By then the same issue has often happened many times.
From requirements to action
We build a monitoring plan from your risk assessment, agree samples, frequency and owners, then carry out the checks, including desk reviews and live attendance at meetings where agreed. Findings, trends and follow-up are reported through your governance.
Monitoring connects to the rest of the programme: findings feed training, SOP updates and CAPA, and routine checks can be automated where that improves consistency, with people making the judgement calls.
What we can take on
What this gives you
Evidence that controls operate in practice, not only on paper
Early warning of recurring issues, by activity, team or market
A monitoring record that supports audits and management reporting
The rules in the UK
UK anti-bribery and fraud guidance both treat monitoring and review as a core part of adequate (bribery) and reasonable (fraud) prevention procedures. These are the main references we design monitoring around. Each summary links to its official source below.
The Ministry of Justice guidance expects a commercial organisation to monitor and review the procedures designed to prevent bribery by persons associated with it, and to make improvements where necessary.
The ECCTA 2023 guidance expects organisations to monitor and review their fraud detection and prevention procedures and make improvements where necessary, including learning from investigations and whistleblowing incidents.
Explains how the UK Serious Fraud Office assesses whether a corporate compliance programme works in practice. It is enforcement guidance, not a pharmaceutical certification standard.
Related article
Managing compliance risks: best practices and strategies. Our article covers how to prioritise and manage compliance risks in practice, including where monitoring fits alongside risk assessment, controls and follow-up.
More reading: PMCPA social media and influencer guidance · Compliance monitoring and data analytics · Pharma Compliance Audits in the UK · Pharma Compliance Readiness Checklist
This overview is informational and does not constitute legal advice. Scope and application should be confirmed for the organisation, activity and counterparty in question. Sources checked September 2026.
Questions, answered
The Ministry of Justice guidance on the Bribery Act 2010 lists monitoring and review as one of its six principles of adequate procedures. The failure to prevent fraud guidance under ECCTA 2023 also lists monitoring and review, including learning from investigations and whistleblowing incidents.
Monitoring is continuous or periodic checking by, or on behalf of, the business, so issues are found and fixed as work happens. An audit is an independent, point-in-time test of whether the programme works. They complement each other.
The highest-risk activities from your risk assessment, typically HCP engagements and contracted services, meetings and hospitality, promotional materials, grants and donations, and payments. The plan sets the sample, frequency, owner and what counts as a finding.
Parts of it can. Workflows and dashboards, for example in SharePoint and Power BI, can flag exceptions and track findings, while experienced people review the results and decide what action is needed.
Each finding is recorded with its root cause, an accountable owner and a due date, tracked through governance, and checked later to confirm the action worked.
Yes, where these activities are within the agreed programme. Monitoring can review contracts, briefings, content approval, disclosures, records and ongoing oversight for external stakeholders or digital influencers acting on a company’s behalf. The scope should reflect the content, channel, country code and responsibility for reviewing or escalating issues.
AI and workflow tools can help route submissions, check required fields, flag potential issues and keep records for copy, meetings and events. They should support the review process rather than make the final compliance decision: qualified company reviewers retain approval authority, assess context and escalate exceptions.
We will listen, ask a few questions and recommend the right scope—without obligation or pressure.
Start a conversation