Pharmaceuticals Undisclosed Interest

Gary Tanner

Head of Business Development  ยท  Valeant Pharmaceuticals International

A Valeant executive managed his company's relationship with a specialty pharmacy while secretly holding a multi-million-dollar personal stake in that same pharmacy.

$9.7 million Amount
2013โ€“2015 Active Period
Convicted at Trial 2019
12 months home confinement; $9.7M forfeiture Sentence
The Conflict Pattern
Undisclosed Interest

An executive managing a company's relationship with an outside vendor held an undisclosed personal financial interest in that vendor โ€” and negotiated terms beneficial to the vendor without disclosing the conflict.

01 Overview

Gary Tanner was Head of Business Development at Valeant Pharmaceuticals, where he managed the company's relationship with Philidor Rx Services, a specialty pharmacy network. According to his 2019 federal conviction, Tanner secretly held a financial interest valued at approximately $9.7 million in Philidor โ€” the very company he was overseeing on Valeant's behalf. He worked to secure an exclusive and lucrative arrangement between Valeant and Philidor while personally standing to gain from Philidor's success. He was convicted of wire fraud and money laundering.

02 How It Worked

1

Tanner was responsible at Valeant for managing and expanding the company's relationship with Philidor, a specialty pharmacy that filled Valeant prescriptions and maximized reimbursements.

2

According to court findings, Tanner simultaneously held a financial interest in Philidor โ€” structured through an intermediary to obscure his ownership โ€” while negotiating and managing the terms of the Valeant-Philidor relationship.

3

He used his position to help secure an exclusive arrangement that enriched Philidor and, through his undisclosed interest, enriched himself.

4

Neither Valeant's management nor its board was disclosed of Tanner's financial stake in the company he was overseeing on the firm's behalf.

03 The Conflict Pattern

Undisclosed Financial Stake in a Business Partner

An executive managing a company's relationship with an outside vendor held an undisclosed personal financial interest in that vendor โ€” and negotiated terms beneficial to the vendor without disclosing the conflict.

04 The ConflictCheck Angle

Why this type of conflict is detectable

This case turns entirely on a single undisclosed relationship: an executive with management authority over an external business relationship had a personal financial stake in the counterparty. An annual conflict-of-interest disclosure process that requires executives to disclose financial interests in all current and prospective business partners would flag exactly this structure.

ConflictCheck does not claim it would have definitively prevented any specific historical fraud. The purpose of this section is to illustrate the type of relationship conflict present in each case and how structured disclosure processes address that category of risk.

05 Outcome

Tanner was convicted in February 2019 on charges of wire fraud and money laundering. He was sentenced to 12 months of home confinement and ordered to forfeit $9.7 million. Philidor's CEO, Andrew Davenport, was also convicted in connection with the same scheme.

Quick Facts
Name Gary Tanner
Role Head of Business Development
Organization Valeant Pharmaceuticals International
Amount $9.7 million
Active Period 2013โ€“2015
Verdict Convicted at Trial
Year 2019
Sentence 12 months home confinement; $9.7M forfeiture
Conflict Type Undisclosed Interest

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