Jorrit Jeroen Water, Novo Nordisk Denmark

Sustainable business

Reporting and transparency

We are accountable for actions and transparent on how we do business

Jorrit Jeroen Water, Novo Nordisk Denmark

Reporting and transparency

We want to be transparent and accountable for how we operate and the transactions that take place when and where we work. 

Since 2004, we have published an integrated annual report that accounts for our financial, social and environmental performance. 

In addition, we account for a fuller picture of our performance and provide transparency on how we account for our actions how we define materiality and work with the Sustainable Development Goals. 

Our reporting focus areas

We operate in 169 countries with vastly different levels of income and health systems. As a global healthcare company, we know that different approaches are needed to ensure that the most vulnerable people receive the care they need. For this reason, we have put in place a number of initiatives aimed at ensuring that vulnerable groups have access to affordable medicines and care.

Our Access to Insulin Commitment
Through our Access to Insulin Commitment we have set a ceiling price of USD 4.00 per 10 ml vial of human insulin offered to governments in 76 low - and middle-income countries and to humanitarian organisations.  

In 2019, the average price the insulin was sold at under the commitment was USD 2.9 per vial, equalling 12 cents per patient per day.1 An estimated 2.9 million people were treated with insulin under this commitment in 2019, of which approximately 200,000 people were reached through sales to humanitarian organisations.  

Beyond this commitment, Novo Nordisk sold human insulin at or below the ceiling price in other countries, reaching an estimated additional 2.2 million people in 2019. 

From August 2020, we have set a new ceiling price of USD 3.00 per 10 ml vial of human insulin.  

See how we work with access and affordability.


Affordability in the US 
Ensuring affordability of medicines within the complex US healthcare system continues to be a high priority. In 2019, we met face-to-face with some of our most vocal critics in the insulin pricing debate – including patients and physicians – to improve our understanding of the affordability challenges that patients are facing.  

We are continuing to launch initiatives to help more people with diabetes access affordable medicine – including those with insurance and those without – as we continue to support a longer-term, systemic reform. 

Our current initiatives in the US include: 

  • A Cash Card Program, offering that for USD 99, people with diabetes can get up to three vials or two packs of FlexPen®/FlexTouch®/PenFill® pens of any combination of Novo Nordisk Inc. insulins. 
  • NovoLog® and NovoLog® Mix follow-on brands made available in vials and pens at a 50 percent list price reduction from the newly established Novo Nordisk Pharma Inc.
  • An immediate, one-time insulin supply option available for people facing an acute need when more time is needed to identify a sustainable solution. 
  • Our Patient Assistance Program providing free medicines, including all Novo Nordisk insulin medications, to eligible patients.  
  • Our human insulin availability at Walmart for about USD 25/vial that has been running for the past 15 years, and recently expanded it to other national pharmacy chains. 
  • Our Co-pay Savings Cards helping to spread the costs of commercially insured patients with high out-of-pocket costs.
  • Enrolment in our Diabetes Patient Assistance Program and an offer to receive insulin free of charge for 90 days for people with diabetes using Novo Nordisk Inc. insulin who have lost health insurance coverage because of a change in job status due to the COVID-19 pandemic.

Find out more about NovoCare® and our insulin affordability initiatives in the US.


Changing Diabetes® in Children
Established in 2009, our Changing Diabetes® in Children programme provides insulin free of charge to clinics caring for children with type 1 diabetes. The programme also supports healthcare capacity building in 14 of the world’s poorest countries.  

In 2019, we enrolled 2,819 additional children, and currently the programme has resulted in:  

  • 26, 500+ children and adolescents enrolled in the programme.
  • 208 clinics established across Bangladesh, Cambodia, Cameroon, Democratic Republic of Congo, Ethiopia, Guinea, India, Ivory Coast, Kenya, Myanmar, Senegal, Sudan, Tanzania and Uganda.  
  • 1,8+ million vials of insulin (100 units) donated to programme clinics. 
  • 15,121 healthcare professionals receiving diabetes care training.  

With the launch of our Defeat Diabetes strategy in 2020, we expanded the programme to reach 100,000 children by 2030.  

Find out more about Changing Diabetes® in Children.


Humanitarian Action
More than 70.8 million people  have been forced to flee their homes and communities due to persecution, violence and human rights violations. This is the highest number since World War II.  

We have built on our Access to Insulin Commitment to improve access to reliable and affordable supplies of insulin to people with diabetes living in humanitarian crises. We have optimised and adapted our ordering and production procedures to better serve the needs of humanitarian organisations. This also includes sharing our knowledge of handling and distributing cold-chain products as well as our experience building capacity to improve access to diabetes care, including supporting the development of education materials on diabetes prevention and care for a humanitarian context.  

Since 2018, we have had a partnership with the International Committee of the Red Cross , the Danish Red Cross to tackle the growing need to improve chronic disease treatment. The aim of the partnership, Partnering for Change, is to ensure the integration of diabetes and hypertension care into the global health operations of the Red Cross Partners.  

The Partnering for Change was established with a three-year time horizon (2018-2020), and in May 2020, the partners agreed to extended with another three-year period to continue in 2021-2023. We work to strengthen capacity to diagnose and treat people affected by humanitarian crises through Partnering for Change with the International Committee of the Red Cross and the Danish Red Cross.  

In 2019, we reached approximately 200,000 people through sales to humanitarian organisation as part of our Access to Insulin Commitment, guaranteeing ceiling price of USD 4.00 per 10 ml vial of human insulin.  

The COVID-19 pandemic continues to challenge relief organisations’ ability to maintain normal operations and uphold their capacity to provide chronic care to patients. To support them in their efforts, we are donating and shipping free insulin to organisations, such as UNICEF, UNRWA and our Red Cross partners, for six months until the end of September 2020. The total value of the donation is more than DKK 20 million. 

To reach other health needs for people living with a rare blood or endocrine disease, we are providing haemophilia and growth hormone products to Direct Relief to support people most at risk in the COVID-19 pandemic. 

Read more about Partnering for Change.


Preventing and treating non-communicable diseases (NCDs)
Rapid changes in demographics and economic growth are causing a surge in the number of people impacted by non-communicable diseases, like diabetes, cardiovascular disease and cancer, in many of the world’s poorest countries.  

Often, non-communicable disease are the result of a combination of genetic, physiological, environmental and behavioural factors, including tobacco use, excess alcohol intake, unhealthy diet with high sugar and salt intake, physical inactivity, and ambient pollution.  

In 2018, we entered into a the Defeat-NCD Partnership to support efforts to both prevent and treat non-communicable diseases in low-resource countries. The public–private–people partnership is hosted by the United Nations Institute for Training and Research (UNITAR) and includes governments, multilateral agencies, civil society, academia, philanthropic foundations and the private sector. 

Defeat-NCDs advocates for universal health coverage for NCDs and is a direct contribution to the Sustainable Development Goals. 

Discover how Defeat-NCDs is making a positive impact on non-communicable diseases.


Reaching the base of the pyramid
In 2010, we established the Base of the Pyramid programme to identify innovative and sustainable solutions to help the working poor living at the base of the economic pyramid.  

The programme is comprised of public–private partnerships with a model that promotes a shared responsibility between Novo Nordisk, governments and various local stakeholders.  

Through these collaborations, the programme supports an integrated approach to diagnosis, treatment and control of diabetes that helps those struggling to cover the cost of treatment and basic necessities like housing, food and transportation. 

The Base of the Pyramid programme has been piloted in Kenya, Ghana and Nigeria. 

Download the ‘Effectiveness, scalability, sustainability and shared value in Kenya’ report.


Foundation support
Our donations to the World Diabetes Foundation and the Novo Nordisk Haemophilia Foundation are recognised as an expense when the donation is paid out or when an unconditional commitment to donate has been made. 

In 2019, we donated DKK 86 million to the World Diabetes Foundation (WDF). The WDF  is an independent trust dedicated to the prevention and treatment of diabetes in developing countries. In 2019, the WDF provided funding to 12 partnership projects in 11 countries. The projects focused on awareness, education and capacity building at local, regional and global levels.  

We have donated a total of DKK 1.69 billion (USD 277 million) to the WDF, to be allocated in the period 2001–2024. 

Visit the World Diabetes Foundation website.


In 2019, we donated DKK 19 million to the Novo Nordisk Haemophilia Foundation (NNHF). The NNHF is a grant-making, non-profit organisation that strives to improve access to care for people with haemophilia and allied bleeding disorders in developing and emerging countries.  

NNHF supports programmes in developing and emerging countries with initiatives focused on capacity building, diagnosis and registry, education and empowerment. Since 2005, NNHF has provided funding for 284 programmes in 75 countries.  

Visit the Novo Nordisk Haemophilia Foundation website.

Counterfeit products pose significant and potentially life-threatening risks to the health of patients. Such products may lack active ingredients so patients do not receive the treatment they expect and need, or they may contain other ingredients that could pose a safety risk.

To ensure patient safety, we have been implementing a comprehensive anti-counterfeit programme. A cross functional Anti-Counterfeit Working Group, chaired by the head of our Customer Complaint Centre, ensures vigilant risk assessment and implementation of an Anti-Counterfeit Product strategy.   

We have an ongoing international collaboration with regulatory bodies, scientific and trade organisations, law enforcement agencies and other stakeholders to investigate counterfeit products and to influence legislation regarding new anti-counterfeit measures. 

Those found guilty of producing or/and distributing counterfeit Novo Nordisk products are given fines and/or custodial sentences. China, as a result of lobbying and official intervention, has increased the length of sentences for counterfeiting.

We are a member of the Pharmaceutical Security Institute (PSI), which on behalf of the approximately 30 largest pharmaceutical companies, collects information and coordinates investigations into counterfeit products worldwide. 

We conduct regular reviews of risks through information exchange with external collaborators. The investigation of suspected counterfeit cases is reported via our affiliates or authorities. Monthly internal counterfeit surveillance reports are reviewed by key specialists and management.

Our Quality Management System identifies and investigates alleged occurrences of counterfeited Novo Nordisk products. In China, we work with local investigation firms to perform market searches to help health authorities track down and seize counterfeit products. Outside China, we conduct investigations of suspected counterfeit products based on risk analysis and take legal action against those involved in the counterfeiting of our products.  

Recognising that low awareness and under-reporting are known issues in many countries, we provide internal video training for our affiliates globally. 

In China, our proactive approach including collaboration with and training of local authorities, and scouting for counterfeit products and reporting these to local authorities has enabled us to keep counterfeit products at a relatively lower level.

Currently, the main products being counterfeited are NovoFine® in China and Norditropin® sold via the internet or in fitness centres.

Diversity & inclusion
We believe that diversity and inclusion in all teams - from entry level to top management - drive better decision making, by ensuring that multiple perspectives are considered. We have a strong stance on the value proposition of diversity in all its forms (gender, nationality, education, experience, age, personality etc.) and encourage all management teams to address and discuss unconscious bias in key decision-making processes.

By the end of 2019, the gender distribution among managers was 60% men and 40% women, unchanged from 2018. 

Our Executive Management team has agreed on a shared rationale for diversity and inclusion in Novo Nordisk, built on four primary drivers:

  1. Broaden our access to talent: We want to attract, develop and utilise the best people with different perspectives, in order to contribute to better business results. We will only succeed in doing so by reflecting and selecting from the widest possible talent pool.

  2. Secure diversity of perspectives: We want diverse perspectives in all our senior management teams, boards and committees to ensure innovative solutions and solidity in complex decision making, addressing the challenges of a growing global organisation with diverse customer needs and societal impact.

  3. Foster a global mindset: We want to develop people with a global mindset and international experience to ensure that our organisation stays agile and prepared for future growth. We strive to provide exciting global career and mobility opportunities for talents and leaders. 

  4. Offer equal opportunities: We want to build a collaborative and engaged global team, by ensuring an inclusive culture, in line with the Novo Nordisk Way, that provides equal opportunities for everyone to thrive and do their best.

We use large amounts of energy, water and raw materials in the production and distribution of our medicines and injection pens. With more than 29 million people relying on our medicine, we recognise our responsibility to address environmental challenges such as global warming, plastic waste and water scarcity. We want our actions to contribute towards a sustainable, healthy environment for the long term. Our ambition is to have zero environmental impact.

CO2 emissions
In 2019, CO2 emissions from operations and transportation increased by 10%. The increase was primarily from product distribution, due to an increase in distributed volume, along with using more air freight than sea freight as a result of supply and market driven-challenges.

CO2 emissions from global offices and laboratories decreased by 54% in 2019, including a significant reduction in CO2 emissions from our R&D site in Beijing after they began sourcing wind power.

As part of our Circular for Zero strategy, all offices and laboratories will source renewable power by 2030.  

In 2020, we anticipate a significant decrease in CO2 emissions due to on-going renewable energy projects, including solar power across all US operations, wind power in Europe and green steam in Denmark. 

CO2 emissions from transportation are also expected to decrease due to a company car policy that encourages transition to hybrid and electric vehicles and through collaboration with EV100.


In 2019, water consumption at production sites increased slightly by 2% compared with 2018. This was due to an increase in water consumption for production of API for Diabetes and Obesity care.

Three facilities, in Algeria, Brazil and China, are in regions subject to high water stress or large seasonal variations, consuming 14% of the total water for global production. There have been no water shortage incidents in 2019 and overall, water consumption at these facilities increased by 2% in 2019.


Waste management
In 2019, waste from production sites decreased by 13% compared with 2018. The amount of waste recycled decreased 8% primarily due to a decrease in organic residues from the fermentation of insulin.

The amount of waste sent for energy recovery decreased by 36% primarily due to the implementation of a distillation method within API production to reuse ethanol instead of sending it for incineration with energy recovery.

Of the total waste from production sites, 93% was recycled, used for biogas production or incinerated at plants where the energy is used for heat and power production.

18% of the waste is categorised as hazardous waste, a decrease from 21% in 2018. This decrease was due to a reduction in ethanol waste from the production of API for diabetes and obesity care products.


Energy consumption
Energy consumption for operations has expanded in scope from covering all facilities at production sites to also include office buildings and laboratories outside of production sites. 

In 2019, energy consumption for operations decreased by 3% compared to 2018. Energy consumption for production decreased 2% due to reduced energy use to produce diabetes finished products. Energy consumption decreased by 10% from offices and laboratories due to various smaller changes across multiple sites.

In 2019, 76% of power used at production sites was sourced from renewable energy, a decrease from 77% in 2018. This is due to lower power consumption at the largest production site in Kalundborg, Denmark which uses wind power. 

In 2020, we switched to solar power in the United States, helping us to achieve 100% renewable power at all production sites.


Task Force on Climate-related Financial Disclosures (TCFD)
The industry-led Task Force on Climate-related Financial Disclosures (TCFD) establishes recommendations for disclosing clear, comparable and consistent information about the risks and opportunities presented by climate change.

We believe that decision-useful climate-related information in mainstream reports is needed more than ever. The TCFD recommendations fit well into our commitment to conduct business in a financially, environmentally and socially responsible way. 

We will take a step-wise approach to incorporate climate-related disclosures as per the TCFD recommendations into our Annual Report.

See how we addresses the risks related to climate change


The use of chemicals is essential in our production of active pharmaceutical ingredients. We strive to avoid the use of hazardous chemicals, and most of the chemicals we use are harmless.

We take strict precautions when we use hazardous chemicals in our production. Finding non-hazardous alternatives and supporting the use of safe chemicals are two of our top priorities.

We work in compliance with present legislation and monitor future legislation very closely. All our manufacturing sites comply with local environmental regulation, and we continuously follow new developments to implement new regulations in due time. Currently, we are focusing on the EU REACH regulation, which urges industry to phase out certain hazardous substances.

Read our REACH Article 33 Statement

Additionally, we are part of the industry-wide cooperation Pharmaceuticals in the Environment (PiE), just as we work closely with The European Federation of Pharmaceutical Industries and Associations (EFPIA) to address the potential environmental impa ct of pharmaceuticals.

We collect waste streams containing chemicals of very high concern, and they are treated by an approved third-party vendor. Thereby we ensure that such substances are not discharged into the nature.


Breaches of regulatory limit values
Breaches of regulatory limit values cover all breaches reported to the environmental authorities. In 2019 there were 16 breaches, a decrease from 27 breaches in 2018. The breaches were mainly related to wastewater, and all had minor impact on the environment.

We are committed to meeting our responsibility to respect human rights as defined by the UN Guiding Principles on Business and Human Rights. As such we will:

  • Identify potential and actual adverse human rights impacts that our operations may cause, contribute to or be directly linked to;
  • Use or establish processes to prevent or mitigate potential adverse impacts on human rights, where identified;
  • Seek to best remediate or participate in the remediation of any actual adverse human rights impacts that our business causes or contributes to;
  • Account for how we address our potential and actual impacts on human rights, where it will not put the people concerned at risk or damage legitimate requirements of commercial confidentiality;
  • Expect our business partners and other parties directly linked to our operations, products or services to meet their responsibility to respect human rights as described by the UN Guiding Principles on Business and Human Rights; including committing to respect all human rights, carrying out human rights due diligence and providing access to remedy when needed;
  • Use leverage to make other parties directly linked to our operations, products or services cease actions or omissions that lead to adverse impacts on human rights once we become aware of such impact.

The responsibility to respect human rights refers to all internationally recognised human rights, including but not limited to prohibition of forced, bonded or debt labour, slavery, servitude and human trafficking.

In implementing the UN Guiding Principles, we will pay particular attention to the rights of, as well as the challenges faced by, vulnerable groups whom we have impacts, such as children and patients, by referring to relevant United Nations instruments (e.g. Convention on the Rights of the Child).

The responsibility of Human Rights is anchored under the Business Ethics Compliance Office (BECO) in Novo Nordisk. The human rights commitment is an integral part of the Business Ethics Code of Conduct and is overseen by the Business Ethics Committee.

This commitment is approved by Lars Fruergaard Jørgensen, President & CEO of Novo Nordisk. (6 December 2018)

UK Modern Slavery Act 
Read our latest and previous statements on the UK Modern Slavery Act
2019  -  2018  -  2017

Our Human Rights impacts
We conduct regular assessment of our risks and impacts on all human rights across our global processes and corporate functions. Among the human rights impacts we have identified, the following were determined as our salient human rights issues and important human rights impacts for 2019-2020. 

These have been prioritised for due diligence and reporting. Find out below how we manage each of these human rights issues and impacts:

  • Access to essential medicines
  • Human biosamples
  • Clinical trials
  • Personal data protection & privacy (see below)
  • Counterfeit products (see below)
  • Patient safety (see below)
  • Local production projects (see below)
  • Human rights in supply chains (see above under Responsible Sourcing)
  • Safe and healthy working conditions (see above under Responsible Workplace)
  • Labour in the workplace  (see above under Responsible Workplace)

We aim to serve patients wherever they are in the world with the highest quality medicines.

When it is optimal for manufacturing to take place in the country where the product will be used, we either collaborate with local partners such as Contract Manufacturing Organisations or create our own production sites. We are currently engaged in projects in several countries with complex operating environments, including Algeria, Iran, Egypt and Saudi Arabia.

We are making progress to embed respect for human rights in the full project lifecycle from idea to execution. Relevant policies to embed respect for human rights include Local Manufacturing Strategy, Investment Policy and Project Execution Model. 

The Local Manufacturing unit in the country where the production project will take place is responsible for project execution. We are ensuring that internal human rights expertise is used to set direction for how respect for human rights is an integral part of the projects.

Where there are publicly known human rights risks in specific operating contexts, we will conduct enhanced human rights due diligence of our own activities and local partners. In addition to desk research and taking into account internal human rights experts’ input, we also draw upon external experts’ input, peers and local knowledge.

Any concern or question regarding our responsible business conduct in local production projects and/or operations can be brought to our  Compliance Hotline  (in over 40 languages).

Every day, millions of people rely on the quality and safety of our products.

All medicines have potential side effects as well as benefits. We routinely monitor the safety and quality of all our products. This includes review of safety data from clinical studies and review of side effects and technical complaints received on marketed products. By monitoring quality and safety information on our products we can take due and appropriate actions to safeguard patient safety if needed.

We have in place a Quality Management System to ensure that we adhere to international and local legislation and that safety information is handled in the same way no matter in which country the patient lives. 

Our Global Safety team has a pharmacovigilance system in place ensuring that the necessary means for collection and notification of any safety data are in place.

Prior to any clinical investigation of a new pharmaceutical product or medical device, a safety committee with members from all relevant functional areas is established. This committee will exist throughout the product or device’s life-cycle. It is a multi-disciplinary team providing assessments of safety data, for a pharmaceutical product or medical device in development or on the market.

Our Quality Management System includes the following process to ensure we continuously assess risks and act upon findings in a timely manner:  

  • Information about side effects, technical complaints and counterfeits are received from multiple sources, for example clinical trial participants, patients, healthcare professionals, partner companies, health authorities and literature
  • This information is entered into our complaint database, and side effects are also transferred and evaluated in the Novo Nordisk safety database
  • Regular analysis of data in the safety database is done to look for patterns associated with complaints, including side effects, such as new types or higher frequency of side effects.
  • In parallel, the health authorities independently review the information. This dual system for surveillance of data ensures optimal patient safety.
  • All relevant safety data from clinical trials, as well as safety data on marketed products, is presented to the safety committee on a regular basis. 
  • The safety committee decides on any necessary actions and the safety committee chairperson ensures actions are communicated to the relevant Novo Nordisk business area(s) for implementation. Actions could include advice on how the medicine should be used, inclusion of new warnings in the package leaflet, or ultimately stopping the use of the product.

Further procedures ensure we can react promptly and adequately if one of our products on the market, or used in clinical trials, is suspected of being affected by a significant product defect, such as recalling affected products.

We are committed to patient safety and want to make it easy for patients to get in contact with us, if they have a complaint or want to report a side effect. Therefore, we have established easily accessible online complaint reporting directions with contact information in local language.

As a healthcare company, we handle large volumes of personal data, including information on participants in clinical trials, human biosample donors, patients and healthcare providers reporting safety concerns, and our employees. 

We store and transfer personal data in and across different jurisdictions on a global level. Our Code of Conduct and Business Ethics Compliance Framework are the basis for our global Personal Data protection Compliance Programme. Together, they set the minimum global standards for how we handle and protect personal data.

We always comply with any stricter local legal requirements for protecting personal data. We recognise that domestic law may not adequately protect the right to privacy in some jurisdictions. Where there is a conflict between the national law and the internationally recognised human rights principle of privacy, we always seek to make a responsible decision about how to handle personal data. 

Our global Personal Data Protection Compliance Programme, including policies, training, and oversight mechanisms, is developed and maintained centrally, but each business area and its management are responsible for ensuring that their operations are in compliance with our internal requirements and applicable law.

Our Personal Data Protection Compliance Programme conducts cross-organisational reviews of risk to privacy in key functional areas to identify where we can reduce data collection and mitigate the highest risk to data subjects.  The Personal Data Protection compliance programme continuously assesses risks and trends and monitors national and international laws to ensure continued compliance. 

Our actions under the Personal Data Protection Compliance Programme include: 

  • Establishing standards detailing how employees must protect personal data;
  • Training employees on how to comply with the standards;
  • Monitoring and auditing to ensure that the standards are effectively implemented;
  • Investigating potential non-compliance and imposing disciplinary sanctions as appropriate;
  • Maintaining processes to allow individuals to request access, correction, and deletion of their personal data, and to object to processing of their data
  • Maintaining processes to promptly respond to personal data breaches

Bioethics is the term we use for all ethical issues related to the use of life science technologies for the discovery, development and production of pharmaceutical products.

We consider the bioethical implications of our research and development activities. We take into account societal concerns on ethical issues related to humans, animals and gene technology when new opportunities arise in research and development methods.

Here, you can find information about our approach to:


Business ethics and anti-corruption
As a global company, we work across many diverse cultures where concepts of appropriate business conduct can vary widely. We believe ethical business conduct is about values and integrity as well as compliance and risk mitigation. Taking a proactive approach in ethical business conduct increases trust in our company and improves relationships with key stakeholders. 

In the Novo Nordisk Way, we outline expectations for employee behaviour by stating that ‘we never compromise on quality and business ethics’ (Essential 10). This is supported by our Business Ethics Code of Conduct and Business Ethics Compliance Framework for how to operate. 

We focus on complying with all local and international anti-corruption laws, principles, standards and codes (including codes developed by patient organisations) and ensuring transparency in all interactions.

We have a Global Business Ethics Compliance programme to ensure compliance with all relevant anti-corruption laws and to work against corruption. The programme has seven elements:

  • Implementing business ethics policies and procedures
  • Designating a compliance officer and compliance committees
  • Conducting effective training and education
  • Developing effective lines of communication
  • Conducting internal monitoring and audits
  • Enforcing standards through well-publicised disciplinary guidelines
  • Responding promptly to detected problems and undertaking corrective action

An annual external review ensures that the programme is improved where needed. Recent improvements include:

  • A Business Ethics Code of Conduct  was launched in January 2017, and updated in 2018, together with an extensive update of all the existing global anti-corruption requirements. 
  • The Business Ethics Compliance Framework, a new internal online guidance tool for all global and local business ethics requirements. The tool ensures consistent and relevant advice to all employees, thereby helping them to make the right decisions in whatever situation they may find themselves
  • The Business Ethics Compliance app, launched in August 2017, ensures that employees, including field-based employees, have access to business ethics requirements, from all iOS devices, whether online or offline

In 2019, as in 2018, 99% of relevant employees were trained in business ethics. 


Responsible sourcing
Our Responsible Sourcing programme aims to ensure that our social and environmental responsibility is reflected throughout the supply chain.

The programme is based on our commitment to the UN Global Compact and the UN Guiding Principles on Business and Human Rights in our supply chain. 

With more than 40,000 suppliers across the globe, our expenses with suppliers accounts for more than a third of our total sales revenue. It is vital that we understand potential risks to responsible business conduct across our global supply chain and take necessary steps to mitigate risks. 

Our Responsible Sourcing Standards for business partners have been implemented globally. Our Standards articulate what we mean by responsible sourcing and make clear our expectations to our suppliers on responsible business conduct within human rights, labour, health & safety, environment and anti-corruption. Our Standards build on international standards and are aligned with the Pharmaceutical Industry Principles for Responsible Supply Chain Management.

Novo Nordisk's Responsible Sourcing Standards for business partners are available in the following languages:

Danish (PDF) | English (PDF) | German (PDF) | French (PDF) | Spanish (PDF)| Chinese (PDF) | Japanese (PDF) | Portuguese (PDF) | Russian (PDF)

Our other declarations, disclosures and statements include: 

The number of audits concluded in 2019 decreased by 20% compared with 2018. The decrease in quality audits was due to the additional qualification audits in 2018 supporting, among others, the diabetes API project in the US. There were no critical findings related to the quality audits, but one critical finding was issued in connection with a responsible sourcing audit regarding working hours. 

An action plan with concrete deadlines has been agreed upon and a responsible sourcing re-audit is planned for 2020 to follow up on improvements.

We provide a workplace that is a safe and promotes both mental and physical health and well-being. Our company culture also plays a strong role in ensuring a diverse, fair and inclusive working environment. Together, this is what determines our ability to attract and develop some of the best talent from all over the world.

Labour rights
Our responsibility to respect labour rights applies to our global operations as a global minimum standard of business conduct. We track labour rights performance for all our employees in the workplace and verify whether labour rights risks are being effectively addressed. 

Our commitment is to continuously protect, prevent, promote, improve and develop. In 2019 we have addressed the following labour rights topics:

  • Revitalised and reinforced our Global Labour Code of Conduct to ensure it was contemporary and in alignment with Novo Nordisk’s Business Ethics Compliance Framework, which includes respect for human rights. The Code of Conduct describes expected global minimum labour rights requirements for Novo Nordisk employees including the principles concerning fundamental rights in the eight ILO Core Conventions and labour rights as stipulated in the International Bill of Human Rights.
  • Entered a 5-year living wage programme with an external global non-profit business network and consultancy. The objective is, to ensure that all Novo Nordisk employees are paid a living wage, i.e. adequate to purchase basic goods and services necessary to achieve a basic standard of living, based on calculations of living wages in the countries we operate in. An analysis indicated that this is the case.
  • Conducted a study on gender and equal pay covering more than 50 countries and over 25,000 employees to identify any differences in pay level or annual bonus due to gender. In a few locations, some differences that need to be further investigated were identified, and if due to gender, corrected. The equal pay study will be repeated in 2020 to ensure a continued focus. 
  • Increased minimum paid maternity leave from 12-14 weeks globally.
  • Introduced right to paid paternity leave.
  • Ensured better coverage of forced and bonded labour/ child labour and young workers and update of Novo Nordisk Modern Slavery Act Statement 2019.
  • Recognised the right to social security and social insurance.
  • Added a new section to our Human Rights Due Diligence process and obligations, i.e. covering how we identify, prevent, mitigate and account for how we address adverse labour rights impacts.

We are committed to continuously oversee and improve labour rights for all our employees in the workplace globally. We publicly communicate on actual and/or potential labour rights risks, infringements, mitigating actions, impacts, continuous improvement in our integrated annual report.

For more information, download our Novo Nordisk Labour code of conduct (PDF)


Health and safety 
We employ more than 43,000 people worldwide. All of them have a fundamental right to a healthy and safe working environment. Supporting their physical health and mental well-being is fundamental for them to grow personally and professionally. 

We offer a healthy and engaging workplace, supported by a comprehensive Health & Safety programme. To this end, we have implemented our Health & Safety management system across our entire global organisation to ensure such conditions for all employees and contractors.

Below are some of the actions taken globally:

  • Developed global leadership guidelines to promote mental well-being and support managers taking responsibility for creating healthy workplaces. On an annual basis, we monitor levels of stress symptoms reported by employees. We train and educate our human resources experts and managers to have open dialogues with teams, so that issues in the psycho-social working environment, which could affect employees, are quickly identified and addressed.
  • Emphasised transport and traffic as a major risk area, particularly for medical representatives working in countries with poor public infrastructure. We have identified measures on transport accidents. Based on these, several initiatives to prevent transport accidents has been initiated in the organisation.
  • Continued to monitor the level of work-related pain annually. Heavy manual lifting has been an ongoing challenge in production facilities and so we have limited this to a 15 kg maximum load. Since 2016, we have minimised these routine heavy lifts in the production facilities. Sedentary work for long periods of time is posing a risk to employees’ short- and long-term health. To overcome this challenge, we have developed and launched a global toolbox offering guidance, tools, and inspiration to drive behavioural change through increased workday activity.
  • Maintained for on workplace health promotion with our novohealth programme. The programme enables employees to act on their health and provides a framework for integrating health promotion into the workday. Managers are responsible for supporting implementation of novohealth and provide opportunities to: engage in physical activity, enjoy healthy food and beverages, work in a smoke-free environment and attend regular health checks. The programme is adapted locally by novohealth ambassadors and its content is co-created by employees across the organisation. 

We are committed to continuously improving safety, ergonomics, and well-being. We have defined our 2020 ambitions and track performance based on these elements: 

  • Safety: zero-injury mindset: Lost Time Accident (LTA)1 frequency (reduction of number of employees with occupational accidents) = 2.0 (= 2.2 in 2019).
  • Well-being: <10% of employees experiencing stress symptoms (= 14% in 2019).
  • Ergonomics: minimum 90% of all employees agrees that their work does not cause physical pain in general (87% in 2019).

The systematic approach to continuous improvements in health and safety has led to improvements in reducing work-related accidents with absence has decreased by 27 % from 2016 to 2019.

Our sustainable tax approach

Our overall guiding principle within tax is to have “a sustainable tax approach”, emphasising our commercial approach to manage the impact of taxes while remaining true to our values of operating our business in a responsible and transparent manner.

We are a multinational company with a vision to bring life-saving medicine to people in need globally. As a global company, a fundamental prerequisite for running our operations across many countries and affiliates is to trade products and services across borders within the Novo Nordisk group of companies. Such cross-border trading is subject to transfer pricing regulations.

Transfer pricing legislation has the purpose of ensuring a fair split of corporate tax revenue between jurisdictions by restricting multinational companies from artificially shifting profits between jurisdictions. Many countries have implemented standards developed by OECD in their domestic transfer pricing regulations. We follow the OECD principles on transfer-pricing and any local requirements, if they deviate from the OECD standard.

We utilise a so-called principal structure for transfer pricing purposes. A principal structure means that all legal entities, except for the principals, perform their functions on contract on behalf of the principals. As a result, entities contracted by the principals are allocated an operating profit according to a benchmarked net profit margin based on activity performed or alternatively an operating profit agreed in an Advance Pricing Agreement (“APA”). The remaining residual profit is subsequently allocated to the principals.

Commercially driven tax approach
Our business structures are based on commercial considerations and hence business substance. Consequently we pay taxes where value is generated. This means that we will manage tax based on commercial considerations while always respecting international and domestic tax rules.

We welcome and make use of tax incentives offered in the jurisdictions where we operate because such incentives help support the necessary R&D activities to develop new cutting-edge pharma products and help reduce the price of such products for end-users, making them accessible to a wider group of patients.

Being a truly global company also means that we do business in low-tax jurisdictions if there is a local demand for our products. Our tax approach does not prevent us from engaging in such business in so far as our activities in those jurisdictions are driven by commercial considerations and not motivated by tax considerations.

Responsible tax approach
As part of our sustainable approach to tax, we are committed to managing taxes in a responsible way. In recognition of this, we for instance do not use artificial structures or tax havens to reduce our tax payments.

We aim to not only comply with the letter of the law, but also the underlying policy intent. When making decisions on tax, we will not take a position in our tax returns unless we feel comfortable that the position we take will be upheld in a court of law if challenged by a tax authority.

We conclude APAs, which are ahead-of-time agreements between tax authorities in two or more countries, determining the appropriate intra-group pricing for certain transactions for a pre-determined amount of time. Putting in place APAs ensures that both Novo Nordisk and the involved tax authorities can agree to the intra-group pricing of our transactions and avoid unnecessary conflict. In addition to concluding a substantial number of APAs, we engage in dialogue with tax authorities on for example binding rulings and new legislative initiatives.

To ensure continuous compliance with our global tax obligations and adherence to our tax approach, we employ qualified tax experts in Novo Nordisk and we continuously monitor new tools and solutions that can help us maintain a high-quality compliance standard. We monitor new legislation and regulatory developments on an on-going basis and assess the impact on Novo Nordisk in order to remain complaint.

Transparent tax approach
As part of our sustainable approach to tax, we are committed to transparency, and we will continue to be open about our tax practices. We also maintain professional and cooperative relationships with local tax authorities built on mutual trust and transparency.

Where possible, we seek to clarify any tax uncertainties with the relevant tax authority before deciding on the appropriate tax treatment. Where we disagree with the position of a tax authority, we will inform the tax authorities thereof and make our views known. If we ultimately fail to come to terms with the tax authority, we will not refrain from bringing cases to the courts to achieve an assertive answer on the correct interpretation.

”A sustainable tax approach” has been approved by the Board of Directors of Novo Nordisk, and all employees in the Novo Nordisk tax organisation are committed to adhering to this tax approach.