Employees and external stakeholders can report suspected misconduct in a secure and confidential manner through the Novo Nordisk Compliance Hotline.
When you have a concern about a possible breach of regulation or internal policies, the right thing is to raise your question or concern to relevant people.
You may use these links for reporting to the Compliance Hotline:
Compliance Hotline reporting portal - Iran (Please use this link if you're located in Iran).
Business Ethics misconduct, which could be a conflict of interest, corruption including payment of bribery or facilitation payments, unethical donations, gifts and entertainment to business partners, public officials or healthcare professionals given by Novo Nordisk employees or third parties acting on behalf of Novo Nordisk, Human Rights abuses or protection of Privacy and Personal Data.
Accounting issues & Fraud, such as theft and embezzlement of Novo Nordisk assets and funds, vendor fraud, acceptance of kickbacks, accounting manipulation, breaches in internal accounting controls and auditing matters.
Quality misconduct impacting GxP related processes which are not being addressed in the regular Quality management system.
Breaches of antitrust or fair-trading legislations, which could be related to misuse of dominant position on a market.
Breaches of environmental legislations, such as possible illegal disposal of waste.
Novo Nordisk Way misconduct, including serious unfair treatment of an individual employee or broader management misbehaviour.
You may also report serious misconduct related to Espionage, Sabotage, Information Security Violations and other breaches that otherwise relate to serious offence or other serious matters.
Individual cases concerning unfair treatment of a single employee will in most cases be handled by Ombudsman falling outside of the investigational process and whistle-blower set-up. You can report cases to Ombudsman via this link: Ombudsman (for Novo Nordisk employees only)
When reporting a case, it will be received by the Audit Committee Secretariat monitored by the Audit Committee, which is part of the Novo Nordisk Board of Directors.
For reports in scope of the investigational process and whistleblower set-up and where an investigation is assessed necessary, an investigation of your concern will be started up including establishment of the relevant investigation team.
The investigation process is outlined below.
Novo Nordisk will not tolerate discrimination or retaliation against reporting persons or persons and companies assisting in making the report who in good faith make a report or persons participating in an investigation. Retaliation occurs when an adverse or credible threat of an adverse action is taken against an employee who in good faith makes a report or participate in an investigation simply because he or she did so.
Examples of retaliation include, but are not limited to:
This procedure does not prohibit adverse action taken against employees for legitimate, non-retaliatory reasons, even if that employee is engaged in protected activity, as long as the adverse action is not directly connected to the reporting or investigation participation.
Whether you provide your name or chose to stay anonymous, Novo Nordisk will diligently ensure your protection to the extent possible and that your identity is not revealed.
If you identify yourself, it increases our ability to investigate the report and maintain the contact for more information and provide feedback to you during the investigation and protect you against potential retaliation.
Your name and identity will be kept confidential and will in general not be shared with persons outside the investigation team. Should sharing of your identity under the circumstances be necessary, we will seek your consent to do so, unless it is specifically permitted not to involve you.
The Investigation Team is working under confidentiality obligations and is trained to safeguard whistleblower reports and investigative information.