Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.
Commitment, principles & goals
We do not tolerate bribery, extortion or corruption. We are expressly committed to fighting these crimes across the globe. The primary policy document governing these issues is the Code of Conduct mentioned under Principles 1 and 2, as well as our Group-wide anti-corruption guideline.
Taking action and gauging the results
Our Code of Conduct and anti-corruption guidelines are applied within our company through our compliance management process, as well as the internal compliance training and workshops mentioned under Principles 1 and 2.
- Global Business Partner Risk Management Policy: We adopted our Global Business Partner Risk Management Policy in 2012. It constitutes a fundamental component of the selection process for business partners, along with their overall assessment. This policy aims to ensure that business partners are selected diligently in order to minimize the danger of legal and financial risks, or damage to our reputation. This process is especially concerned with fighting corrupt practices.
- Guidelines on interactions with the health industry: Our Compliance Policies for our Biopharma and Consumer Health businesses guide our employees' interactions with medical professionals and other representatives of the health industry. These guidelines aim to ensure that all payments are made for a legally valid reason and never in exchange for prescribing our products. The policies are backed by a modern electronic compliance management system in which interactions with medical professionals and other representatives of the health industry are recommended, approved, documented, monitored, and, as relevant, disclosed. Our suppliers are subject to the supplier management process that is likewise described in these guidelines.
In Europe effective 2016, companies must disclose all donations not connected to research that are made to physicians and healthcare organizations, with the recipients individually named. This is a requirement stipulated by the transparency initiative of the European Federation of Pharmaceutical Industries and Associations (EFPIA). Our Compliance organization started initiating the measures necessary to satisfy this disclosure obligation in 2014. Our goal is to disclose the required information by June 30, 2016.
- Code of Conduct audits: In order to monitor and assess adherence to our Code of Conduct within our company as well as among our suppliers, we conduct the audits described under Principles 1 and 2. We furthermore have a Speak-Up Line that allows employees to report compliance violations. In 2015, 49 audits were conducted with respect to corruption.