Whistleblower reporting policy

Reporting and receipt of complaints

Novo Nordisk has made it possible for employees, agents and other stakeholders to report any suspected violations or concerns regarding financial fraud or business ethics.

In case you wish to refer such an issue or make such a complaint, you can report this to the Audit Committee of Novo Nordisk.

A complaint can be made via hotline, website or by ordinary mail to the following address:

Audit Committee,
Novo Nordisk A/S,
Novo Allé, 2880 Bagsværd,
Denmark.

The members of the Audit Committee are Kurt Anker Nielsen (Chairman), Niels Jacobsen and Jørgen Wedel.

Before you submit your concern, please note the following:

  • All communication made by you in the following will be anonymous and confidential unless you directly instruct otherwise.

  • You are encouraged to identify and explain your concern in sufficient detail to facilitate investigation of the matter. In order to assist the company in conducting an investigation of a complaint, please provide as much information as possible. Employees and agents should not attempt to conduct individual investigation to determine whether or not there has been a violation of this policy, but rather promptly report any suspected violation to the company in the manner set forth herein.

 

Receipt and retention of complaints and investigation

Each complaint, concern or other communication will be received by the Audit Committee. The Committee Chairman, or individual member as appropriate, will investigate the complaint, concern or communication and proceed accordingly in determining appropriate action. The Audit Committee will retain records of such complaints. As the company wishes to encourage good faith reporting of any violation of this policy while avoiding damage to the reputation of innocent persons initially suspected of wrongful misconduct, the investigation will be conducted in a confidential manner to the maximum extent consistent with a thorough and complete investigation.

Remedial Action

If the Audit Committee determines any violation to this policy, appropriate remedial action will be taken.

No discrimination or retaliation

Novo Nordisk will ensure that there will be no discriminatory or retaliatory action against any employee or agent who reports a complaint or concern to the company or any federal agency in good faith based on his/her personal knowledge. If any employee or agent believes that he or she has been retaliated against for reporting or participating in an investigation, he/she should immediately report such perceived retaliation to the Audit Committee. All such reports will also be investigated confidentially.

Any questions about this policy should be directed to:

Novo Nordisk A/S,
GIA, AC Secretary
Att: Mr. Kurt Hungeberg
Novo Allé, 2880 Bagsværd,
Denmark.