For Novo Nordisk, business ethics is about how we think and how we act in the market place. Doing business globally entails many challenges, particularly when working in diverse cultures where the understanding of what constitutes appropriate business conduct can vary widely.
Ethical business conduct is about values and integrity as well as compliance and risk mitigation. The Novo Nordisk Way outlines expectations for employee behaviour by stating that ‘we never compromise on quality and business ethics’ (Essential 10), which is also supported by our business ethics policy as well as detailed procedures for how to operate.
Seven elements for a strong business ethics programme
Business ethics in Novo Nordisk is structured around seven pillars for a strong compliance programme.
Trends, risks and procedures
Novo Nordisk has in place four global business ethics procedures which lay down minimum global requirements for employees and third parties. The four procedures are:
- Business ethics – dealing with matters such as conflicts of interest, fraud, bribery, facilitation payments, donations and grants, gifts and hospitality, and interaction with public officials.
- Interaction with Health Care Professionals – covering promotion of pharmaceuticals and standards for ethical interaction with healthcare professionals.
- Interaction with Third Party Representatives – setting out requirements for how to deal with third parties who act on our behalf toward external parties, incl. public officials and healthcare professionals.
- Off-label communication – setting out requirements for when and how to engage in off-label communication concerning our products.
In addition, reporting on business ethics trends and risks is integrated in our corporate risk reporting and management system.
Governance and coordination
The business ethics policy is supported by a global business ethics strategy overseen by Executive Management, and implemented by the Business Ethics Board, which has representation from Executive Management and senior management from the regions in which we operate. The Business Ethics Board ensures on-going development of a global compliance programme, monitors business ethics risks and reports to Novo Nordisk’s Audit Committee under the Board of Directors.
All Novo Nordisk employees are trained in business ethics. In addition, more focused and detailed training, which include e-learning, workshops, and train-the-trainer sessions, takes place in relevant parts of the organisation – including in sales and marketing. A significant number of face-to-face training sessions takes place every year and is integrated in all onboarding programmes for new employees and in management development programmes.
Effective lines of communication
Since 2004, Novo Nordisk has had a Compliance Hotline that allows employees and other stakeholders to report suspected financial fraud, business ethics misconduct, breaches of the Novo Nordisk Way and quality issues anonymously or by providing their identity. In addition, all employees are required to report suspected misconduct within financial fraud and business ethics to the Audit Committee Secretariat through internal reporting lines.
Auditing and monitoring
Novo Nordisk has mechanisms in place that enables the organisation to promptly detect problems and undertake corrective actions. The internal audit function plays a critical role in assessing adherence to the company’s business ethics policy, by conducting specific business ethics reviews, which include on-site visits, during which auditors interview local management, employees or third parties to assess knowledge and implementation of our business ethics procedures.
Further, Novo Nordisk use internal facilitations (value audits) to ensure compliance with our business ethics requirements. Facilitations are conducted by a group of senior employees with deep understanding of our business and business environment.
Novo Nordisk has implemented global guidelines for misconducts. All substantiated cases are followed by a sanction ranging from verbal warning to termination in the most significant cases.
Investigations and corrective actions
Investigations in all regions are performed in accordance with a global compliance investigation manual.
All significant cases are communicated in details to the Audit Committee.
For more information on our 2012 performance, see pp. 95 in our Annual Report 2012.
For more information about our approach to labour, see our reporting to UN Global Compact Communication on Progress, Part 1, Principle 10.