Disclosure on Management Approach: Society
Organisation
- The Business Ethics Steering Committee is the formal body for driving the preparation of the Business Ethics Policy and procedures as well as outlining the implementation programme. It is a cross-functional group with representatives from across the business, chaired by Lise Kingo, executive vice president and chief of staffs. The committee addresses business ethics in the context of all aspects of the business, including R&D, production, sales and marketing, sourcing and public policy engagement.
- The Global Public Affairs Forum coordinates and aligns global public policy engagement activities in terms of strategic direction and ethical conduct.
- The TBL Leadership Forum is a body with a cross-cutting remit spanning all Triple Bottom Line (TBL) issues, aiming to secure implementation and development of Novo Nordisk’s TBL strategy. The forum is chaired by Lise Kingo, executive vice president and chief of staffs.
Policy
The Novo Nordisk Way of Management’s Business Ethics Policy sets direction and states that bribery and corruption are unacceptable. It also commits Novo Nordisk to adhere to the principles of the UN Convention against Corruption, It is backed by three procedures for ethical business conduct, product promotion and contracting with agents and other third parties. The Legal Policy prohibits anti-competitive behaviour.
Goals
In 2007, the business ethics programme was anchored within the Balanced Scorecard against which individual managers’ performance is assessed annually. Business Ethics will continue to be on the Balanced Scorecard in 2008 including training targets and follow-up related to GIA Business Ethics observations.
Training and monitoring
The company's Executive Management team and the members of the Senior Management Board attended training workshops during 2006, as did all line managers within procurement and sales and marketing. The aim was to provide guidance on how to live up to the Business Ethics Policy, which was introduced in 2005. In addition, all Novo Nordisk's managers and relevant employees in their units have completed an e-learning module on business ethics. This programme is now also a mandatory part of the new managers training. Any employee may complete the e-learning programme, and during 2006 nearly 2,700 employees (close to 10% of the total workforce) took part. In 2007, 95% of all employees within sales and marketing were included in an annual training plan with face to face training on Business Ethics.
Group Internal Audit oversees compliance with the Business Ethics Policy and procedures. The GIA Business Ethics Assurance team conducts both announced and unannounced reviews of business units worldwide. In 2007 more than 25 such reviews were conducted, and recommendations resulting from these reviews are followed-up throughout the year.
Business ethics is also addressed in regular facilitations that serve as audits of adherence to the Novo Nordisk Way of Management, including company policies. Concerns over possible breaches of ethical business conduct and financial fraud can be raised anonymously, and with no subsequent disciplinary or retaliatory action towards the whistleblower, to the Board of Directors’ Audit Committee via a whistleblower mechanism.
The Global Public Affairs Forum meets 3-4 times per year to monitor progress in implementing the Global Public Affairs Strategy, align the company’s approach to public policy engagement and to agree on ethical standards of conduct.
