We are committed to meeting our responsibility to respect human
rights as defined by the UN Guiding Principles on Business and Human
Rights. That means we recognise our responsibility to respect all
internationally recognised human rights across our own activities and
business relationships. Read Novo Nordisk’s Human Rights
Commitment here .
Our Human Rights Commitment is an integral part
of Novo Nordisk Business Ethics Code of Conduct which applies
to all Novo Nordisk employees. Business ethics including human rights
is overseen by the Business Ethics Committee, comprising the Chief
Executive Officer, Chief Compliance Officer and the Chief Legal
Officer among others.
Novo Nordisk’s human rights responsibility is anchored in the
Business Ethics Compliance Office (BECO). Novo Nordisk’s Global
Business Ethics Compliance Programme has integrated respect for human
rights in all its key elements, i.e. governance, training, risk
management, monitoring, tracking and evaluation.
The Global Compliance Forum representing the Global Compliance
Organisation meets quarterly to discuss operational matters to drive
implementation of the Global Business Ethics Compliance Programme.
Embedding respect for Human Rights
Our Human Rights Commitment has been translated
into the Novo Nordisk corporate human rights requirements that set
human rights expectations to all our employees globally. Novo Nordisk
requires employees to reflect respect for human rights in their daily
decisions and actions, which are in short:
1) Avoid causing or contributing to
negative human rights impacts in all business activities
2) Set human rights expectations to
our business partners, with focus on high-risk activities
3) Report human rights concerns to
Nordisk Compliance Hotline. Prevent and mitigate recurrence of
actual negative human rights impacts, with focus on severe impacts.
To implement the corporate human rights requirements across the
company, human rights training of business areas including global
operations are conducted regularly by our internal human rights
expert. Training tools are also provided to business areas in order to
support local implementation of the corporate human rights requirements.
In addition, other channels are used to continuously motivate
managers and employees to continuously develop human rights awareness
and ethics mindset. These include Human Rights Day campaign activities
across the global operations and HQs, e-learning, games, monthly
Business Ethics newsletters, quarterly webinars, internal articles and
internal social media campaigns. On the Human Rights Day internal
campaign in 2020, our Chief Executive Officer called for every
employee to be a human rights champion. In addition, mandatory annual
Business Ethics tests ensure that all relevant employees have basic
business ethics awareness.
Human rights risk management and due diligence
Novo Nordisk integrated human rights risks and data protection risks
to Novo Nordisk’s bi-annual global business ethics risk reporting
process. All business areas are required to identify, assess,
mitigate, prevent, track and report human rights risks along with
anti-bribery and corruption risks and data protection risks.
The scope of human rights risks includes Novo Nordisk’s potential
and actual impacts on all internationally recognised human rights.
Training of global legal and compliance professionals has been
conducted, which guides that ‘risk to people’ is the starting point of
human rights risk management. Human rights risks regarding i)
patients, ii) employees, iii) other workers and iv) community members
and other individuals, are reported into our internal risk reporting
and management platform.
Our risk assessment methodology includes consideration of
‘irremediability’ and scale of ‘harms to people’. Top risks from
across the global organisation are elevated for review and approval by
the Global Compliance Forum, which then submits the top business
ethics risks to the Business Ethics Committee for review and
approval. The top risks are reported to the Board of Directors
annually. We are committed to continuously improving the quality of
human rights risk management through continued awareness and training
on human rights risks.
Novo Nordisk is on a journey to continuously improve the management
of risks of involvement in negative human rights impacts through our
business relationships. For example, it is our corporate requirement
that contractual agreements with all our third party representatives,
among other business partners, should include our Business Ethics
clauses that set human rights expectations according to the UN Guiding Principles on Business and Human
Rights. We have been implementing risk-based business ethics due
diligence for third party representatives. We conduct risk assessment
for each third party representative to determine individual risk level.
In 2020 we initiated analysis of our customers to identify where
human rights risks are in our downstream value chain and how to
strengthen our business ethics due diligence for third party
representatives, which we seek to integrate into our systems. We set
our human rights expectations to suppliers through Novo Nordisk Responsible Sourcing Standards.
Read more about Responsible Sourcing programme under Supplier Audits below.
Our Human Rights impacts
Among the human rights impacts
we have identified through the above-mentioned risk management and due
diligence, the following were determined as our salient human rights
issues and important human rights impacts.
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
- Personal data protection &
privacy (see Business ethics)
- Counterfeit products (see
Patient safety & product quality)
- Patient safety (see
Patient safety & product quality)
- Human rights in
supply chains (see Supplier audits)
- Safe and healthy
working conditions (see Health & safety)
- Labour in the
workplace (see Employees)
Stakeholder engagement and collaboration
We engage with peers and experts to seek continuous
improvements in our approach, including:
The Global Business
Initiative on Human Rights (GBI)
The Nordic Business Network for Human Rights (NBNHR)
Pharmaceutical Supply Chain Initiative (PSCI)
Ethical Trading Initiative (DIEH)
Novo Nordisk requires all employees to report concerns of all
potential and actual severe human rights impacts to the Novo
Nordisk Compliance Hotline, and encourage them to report
all their human rights concerns anyway. This is part of our
corporate human rights requirements and employees receive training
as described above under Embedding respect for Human Rights.
Nordisk Compliance Hotline receives complains and concerns
about human rights from third parties and any individuals. Please
note that customer complaints, side effects or falsified products
should be reported to Report a
side effect (novonordisk.com)
Our corporate human rights requirements that apply to all Novo
Nordisk employees require that actual negative human rights impacts
caused or contributed by Novo Nordisk’s activities or decisions should
be provided with remedy. For remediation of negative human rights
impacts in our salient human rights issues, see above each salient
human rights issue.
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Modern Slavery Acts
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