Corruption in Healthcare. Corruption is a concrete, evolving compliance risk for life
sciences companies, not just a hypothetical risk. In my experience sitting on supervisory boards under Legislative Decree 231/2001 on corporate criminal liability, the risks in this space have grown more sophisticated and harder to detect over the years.

The numbers explain why. Italy’s National Anti-Corruption Authority (ANAC) recently noted
that roughly 25% of all public procurement spending in Italy flows to the healthcare sector, and
that 8% of whistleblowing reports concern that same sector. Those two figures alone justify
heightened scrutiny.

ANAC has been paying attention accordingly. It has adopted the “Catalogue of Corruption Risks
and Prevention Measures in the Healthcare Sector” (Catalogo dei rischi corruttivi e delle misure
di prevenzione nel settore sanitario), approved by ANAC’s Board with Resolution No. 318 of 29
July 2026. The Catalogue is meant to support National Health Service entities in drafting the “corruption risks and transparency” sub-section of their Integrated Activity and Organization Plan (PIAO), and it is a document worth reading well beyond that immediate audience.

The idea behind it is straightforward: healthcare is complex, the stakes are high, and the web of
relationships within the system calls for extra scrutiny, especially when public health is on the
line.

What the Catalogue Covers. The Catalogue maps new risks and new prevention measures across a wide range of areas: healthcare system regulation, biomedical research, pharmaceutical and medical-device marketing and promotion, public procurement, product distribution and storage, financial resource management, human resource management, and the actual delivery of healthcare services, including relations with accredited providers, oversight and inspection activity, and private practice and waiting lists.

For life sciences companies, the marketing and promotion chapter is the most direct point of
relevance: it is the clearest line connecting the Catalogue’s healthcare-system focus back to
industry conduct rather than treating it as a purely public-sector document.

Why This Matters. Healthcare is a perfect storm for integrity risk: high-stakes decisions, significant economic interests, constant public-private interaction, and pronounced information asymmetries. That mix can easily breed mismanagement, conflicts of interest, and outright corruption. ANAC’s own conclusion is that preventing corruption in healthcare takes a model built on transparency and impartiality, digitalization, independent controls, accountability, and the capacity to monitor the most exposed processes on an ongoing basis.

A Basis to Stress Test the Risk Map. Both public entities and private companies active in healthcare should take note of these risks and move to adopt measures that prevent them. For life sciences companies operating a Legislative Decree 231/2001 compliance model, the Catalogue is more than a general awareness exercise: it is a ready-made checklist against which to stress-test the existing risk map, refine the questions asked of management, and confirm that prevention measures keep pace with how these risks.