Every year we use large amounts of energy to manufacture medicines, and the expectation is that production will continue to increase, hence so will our energy consumption. Reducing energy consumption and ensuring that we transition to renewable energy are top priorities. 

As part of our environmental strategy, Circular for Zero, we have set the target, that all offices and laboratories will source renewable power by 2030.

As part of our ambition to switch to circular sourcing and procurement, we collaborate with suppliers to encourage them to shift to sustainably sourced materials, thus reducing our environmental impact. In 2020 we set an ambitious target that all our direct suppliers should source 100% renewable power by 2030 when supplying us. To achieve this, we will work with our suppliers to help them in this transition to renewable power. Successful conversion among our 60,000 suppliers would result in around 300,000 tonnes of CO2 being eliminated from our direct suppliers each year.


Energy consumption for production increased by 11% primarily due to a new API production facility in Clayton, North Carolina. Energy consumption in office buildings and laboratories decreased by 12% due to both energy saving projects and COVID-19 shutdowns. Energy saving projects implemented in 2020 within production sites are expected to result in annual savings of 94,000GJ. 

In 2020, 100% of power sourced at production sites was from renewable energy, an increase from 76% in 2019, meeting our ambition of sourcing 100% renewable power in our global production. This is due to five production sites, including North America, Russia, and France, now also sourcing renewable power starting in 2020. In the process, we became the first pharmaceutical company in the renewable power partnership, RE100, to do this.


Every year we use billions of litres of water. All our production sites are certified according to ISO14001. This means we are committed to continuous improvements, which also includes optimising water use. Each production facility has the opportunity to submit water innovation projects for approval, leading to an overall decrease in water use. It is our goal to achieve ‘no waste of water’ by optimising production, using existing production capacity better and by reusing water whenever possible.

We continuously monitor and report on water use at all production sites globally. Water is included as one of the three prioritised areas in our environmental strategy, Circular for Zero, with a focus on reducing water use and reusing water whenever possible at our production sites.

Annual water targets for relevant business units are in place to increase water use efficiency and the reuse of water. We acknowledge that water use should ideally decrease, but increased water use is a natural consequence of increased production to meet market demands for our products. We strive to decrease our water use relative to production output. 

For information about our position on water, click here.


In 2020, production sites consumed 3,368,000 cubic meters of water, an increase of 7% compared with 2019 due to the start-up of new API production facility in Clayton, North Carolina. Four production sites, including Brazil and China, are in regions subject to high water stress or large seasonal variations. They consume 11% of the total water for global production. Overall, water consumption at these facilities decreased by 15% in 2020, despite adding new sites. This was due to significant water saving projects implemented in China and Brazil.


As a global company, we must think beyond our own operations when considering our environmental impact. Today, our supply chain accounts for 80% of our total CO2 emissions. For us to achieve our ultimate goal of becoming a fully circular company, we have to also look carefully at the companies we work with.

As part of our ambition to switch to circular sourcing and procurement, we collaborate with suppliers to encourage them to shift to sustainably sourced materials, thus reducing our environmental impact. In 2020 we set an ambitious target that all our direct suppliers should source 100% renewable power by 2030 when supplying us. To achieve this, we will work with our suppliers to help them in this transition to renewable power. Successful conversion among our 60,000 suppliers would result in around 300,000 tonnes of CO2 being eliminated from our direct suppliers each year.

We have also set a target to have zero CO2 emissions from operations and transportation by 2030 including all of scope 1 and scope 2 as well as emissions from scope 3 (distribution and business flights).

For more information about our position on climate, click here.


Novo Nordisk has a long-term target of zero CO2 emissions from operations and transportation by 2030. 

In 2020, CO2 emissions from operations and transportation decreased by 44% to 170,000 tonnes:

CO2 emissions from production decreased by 57% due to the implementation of renewable heat and steam in Kalundborg, Denmark, wind power in France, Algeria and Russia, and solar power in the USA.  

CO2 emissions from global offices and laboratories decreased by 38% in 2020. As part of the environmental strategy, Circular for Zero, all offices and laboratories will source renewable power by 2030. In 2020, CO2 emissions from office buildings and laboratories decreased primarily due to energy saving projects and impacts from COVID-19. 

In 2020, emissions from product distribution decreased by 24% primarily driven by optimisation projects to move products shipped from air to sea freight despite supply and market challenges.

Due to the impacts from COVID-19, CO2 emissions from business flights decreased by 71%, and emissions from company cars decreased by 27%.


We distribute hundreds of millions of vials and injection pens to people who need them – and demand for our life-saving treatments is growing. Our products are made of high-quality materials, but after use, most of them end up in landfill.

We are re-designing both our existing and future products to reduce our waste. From the raw materials that go into them to the way they are put together, we are working to solve the end-of-life challenge of devices so materials can be recovered and recycled into new products.

For people living with diabetes, their insulin pen is an essential daily companion. But even if an insulin pen consists of around 77% plastic, it cannot be thrown into the plastic recycling bin along with empty juice bottles and recyclable food packaging. Current guidance varies from country to country, but often used insulin pens end up in general household waste.

We are working to ensure existing and new products are fit for circularity and have developed a circular design guideline within R&D to reduce the environmental footprint of our devices. As part of our environmental strategy, Circular for Zero strategy, we are seeking to address the end-of-life challenges associated with many of our medical devices. In late 2020, we initiated a pilot take-back scheme for medical devices in Denmark with the aim of scaling globally in the future. Through recycling our production waste, we have been able to successfully recycle insulin pens, providing materials for the manufacture of lamps and office furniture. We are pursuing greater re-use and recycling of our devices and aspire to achieve this in coming years.


In 2020, waste from production sites increased by 14% compared with 2019. The amount of waste recycled increased by 20% in 2020 primarily due to an increase in production in Kalundborg, Denmark. The amount of waste sent for energy recovery decreased by 17% primarily due to a distillation method within API production to reuse ethanol internally instead of sending it for incineration with energy recovery. In 2020, 93% of the total waste from production sites was recycled, used for biogas production or incinerated at plants where the energy is used for heat and power production. Less than 1% of total waste was sent to landfill. 14% of the waste is categorised as hazardous waste, a decrease from 18% in 2019. This reduction was due to a reduction in ethanol waste from the production of API for Diabetes and Obesity care.


According to the International Diabetes Federation (IDF), today, one in every 11 people in the world is living with diabetes, a figure that is projected to rise to one in nine by 2045 if action is not taken. Diabetes places a great burden on health systems, and we are committed to working with health authorities and other partners to prevent and treat the disease.

In May 2020, Novo Nordisk launched a new social responsibility strategy, Defeat Diabetes. The strategy introduces new long-term ambitions to accelerate prevention to halt the rise of diabetes, provide access to affordable care for vulnerable patients in every country and to continue to drive innovation to improve lives. First step in the strategy is to reduce the ceiling price of human insulin from USD 4 to USD 3 per vial in 76 low- and middle-income countries and to expand the aspiration in the Changing Diabetes® in Children programme to reach 100,000 children by 2030, up from 25,000. The programme provides care and life-saving medicine for children with type 1 diabetes in low-resource settings. Furthermore, the Partnering for Change programme with the International Committee of the Red Cross and the Danish Red Cross, supporting care for people with serious chronic diseases in humanitarian crises, is also being extended. 

Affordability of medicines is a global challenge and we know that some people in the USA living with diabetes are increasingly finding it hard to pay for their healthcare, including our diabetes medicines. Ensuring access and affordability is a responsibility we share with all involved in healthcare.

For information additional information about our approach to access & affordability, click here.

For information about how we work with prevention of chronic diseases, click here.


The estimated number of full-year patients reached with Novo Nordisk's Diabetes care products increased from 30.0 million in 2019 to 32.8. million in 2020. This 9% increase was primarily driven by sales of long-acting, premix and fast-acting insulins, human insulin and GLP-1 products.

In 2020, the estimated number of patients reached with Novo Nordisk's Diabetes care products via the Access to Insulin Commitment was 3.2 million, compared with 2.9 million in 2019. Novo Nordisk sold insulin according to this commitment in 34 countries of the 76 countries in scope. Beyond this scheme, Novo Nordisk also sold human insulin below the ceiling price in other countries, reaching an estimated additional 3.1 million patients in 2020. Approximately 130,000 patients were reached through human insulin vial donations to humanitarian organisations.

Through the Changing Diabetes® in Children programme, 28,296 children had been reached by the end of 2020, compared with 25,695 in 2019.


During 2020 we increased our donations, partly to respond to COVID-19. As new issues continue to develop, we are working with health authorities and international bodies responding to the COVID-19 pandemic to see how we can make meaningful contributions. Our efforts to support communities are on-going. 

Novo Nordisk makes annual donations to the World Diabetes Foundation (WDF), an independent trust, supports sustainable partnerships and acts as a catalyst to help others do more, and the Novo Nordisk Haemophilia Foundation (NNHF).


In 2020, Novo Nordisk donated DKK 138 million to the WDF, which provided funding to 21 partnership projects in 22 countries. The projects focus on awareness, education, and capacity-building at local, regional, and global levels. See note 5.2 in the consolidated financial statements and worlddiabetesfoundation.org for additional information.

In 2020, Novo Nordisk donated DKK 20 million to the NNHF, which supports programmes in low- and middle-income countries. Initiatives focus on capacity building, diagnosis and registry, awareness, and advocacy. Since 2005, the NNHF has provided funding for 296 programmes in 78 countries. See nnhf.org.

Furthermore, DKK 165 million was granted to the Antimicrobial Resistance Research (AMR) Action Fund, the largest collective fund ever established to support vital research into antimicrobial resistance research and development. It is categorised as an equity investment and therefore not expensed in the income statement.

We provide a workplace that is a safe and promotes both mental and physical health, and overall 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.

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. 

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

We employ people in 80 countries globally. Since 2014, we have been a part of the living wage programme with an external global non-profit business network and consultancy. The objective is to ensure that all our 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.


In 2020, the number of employees increased to 45,323 compared with 43,258 employees in 2019. The growth in employees was mainly driven by International Operations, with the highest growth rate in China.

Novo Nordisk also continues to increase the number of employees in Global Business Services in India, which grew by 14% compared with last year.

The employee turnover rate decreased significantly from 11.4% in 2019 to 7.9% in 2020 and it is assumed to be related to the COVID-19 pandemic.


We employ more than 43,000 people worldwide, all of which have a fundamental right to a healthy and safe working environment. Supporting physical health and mental well-being is fundamental 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 we have 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 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. 


In 2020, the average frequency rate of occupational accidents with absence was 1.3 accidents per million working hours, compared with 2.2 in 2019, due to a 39% decrease in the number of accidents. In 2020, as in 2019, Novo Nordisk had one work-related fatality. The significant decrease in the number of occupational accidents is attributed to the global COVID-19 related lockdown. Our production sites, which have remained in operation during the lockdown, also show a decline in the number of occupational accidents with absence. Novo Nordisk works with a zero-injury mindset and has a long-term commitment to continuously improving safety performance.

Currently, it is not possible to examine the complex interactions in a living organism solely through the use of cell cultures and tissues. Hence, research using living animals is essential for all pharmaceutical companies in the discovery, development and production of new pharmaceutical and medical products.

We recognise that not all research using animals can be replaced in the foreseeable future and consider it our responsibility to actively support the principles of the 3Rs (Reduce, Refine and Replace research using animals, Professor William Russell and Rex Burch, 1959) internally and externally.

Animal welfare is our highest priority. We have a centralised strategic department that contributes to internal awareness and education as well as ensure continued integration of the 3R considerations in our decision-making processes. Furthermore, the department engages in dialogues and partnerships with our key stakeholders.

When animals are necessary for research, their welfare is given high priority and attention in several ways. Not only when they are being tested, but also when they are housed.

Our state-of-the-art housing standards consider the physiological and ethological (behavioural) needs of the animals. We have successfully been able to implement the standards for all animals housed at our facilities.

The design of our renovated facilities was made in close collaboration with The Danish Animal Welfare Society and with valuable input from many internationally recognised experts within animal welfare, as well as input from the employees working every day with the animals, especially the animal caretakers.

For additional information about animal ethics, click here.


The number of animals purchased for research increased from 49,637 in 2019 to 50,036 in 2020. This 1% increase was due to the purchase of fish. The overall development reflects the changes in stages of the different research projects, however, for 2020 the animals purchased for research are also impacted by the overall COVID-19 situation. The reduction in the number of rodents purchased, also reflects Novo Nordisk's continuous focus on reducing the number of animals per research project. 78% of the animals purchased were rodents.


Diversity & inclusion
Being a sustainable employer offering an inclusive and diverse working environment is an integrated part of being a sustainable business. While a number of initiatives have been launched to progress gender diversity in Novo Nordisk, only gradual progress has been made as the current share of women in senior leadership positions is 35% (defined as vice presidents, corporate vice presidents, senior vice presidents and executive vice presidents).

To underline Novo Nordisk’s commitment, accelerate progress and ensure leadership accountability, Novo Nordisk has defined the following global aspirational targets:

  • Create an inclusive culture where all employees have a sense of belonging and equitable opportunities to realise
    their potential
  • Achieve a balanced gender representation across all managerial levels
  • Achieve a minimum of 45% women and a minimum of 45% men in senior leadership positions by the end of 2025

Balanced is defined as the range between 45%-55% to leave up to 10% flexibility for women and men and also allow for non-binary gender recognising that some employees may not wish to be categorised.

While gender is one dimension of diversity, Novo Nordisk fully recognises that diversity is any dimension that differentiates people and enables a diverse line of thought.

All management teams, from entry level upwards, are encouraged to focus on enhanced diversity, with the aim of ensuring a robust pipeline of talent for management positions. Gender diversity in management overall was 59% men and 41% women in 2020 compared with 60% men and 40% women in 2019. Among employees as a whole, the gender split was 49% women and 51% men in 2020, the same as in 2019. Gender diversity at BoD level was 62% men and 38% women, same as in 2019.

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 the Novo 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
In 2020, 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 medicines
  • Human biosamples
  • Clinical trials
  • 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)

The UN Global Compact

The Pharmaceutical Supply Chain Initiative (PSCI)

The Danish 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. The Novo 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.  

Modern Slavery Statement
Read our latest and previous statements on the UK and Australia Modern Slavery Acts

2020  -  2019  -  2018  -  2017

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

Personal data protection and privacy

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


Annual training in business ethics is mandatory for all employees, including all new hires. In 2020, 99% of employees completed and documented their training, with the remaining 1% missing mainly due to employees being on leave. In 2020, 32 business ethics reviews were completed, compared with 34 reviews in 2019. Consolidated findings are reported to our Executive Management and the Audit Committee. 

During COVID-19, all audits outside Denmark were conducted virtually. Despite the changed approach for 2020, Group Internal Audit assesses that the level of business ethics compliance is sound. Management action plans and closure of findings progressed as planned, and there were no overdue management actions or findings at the end of the year.

The Novo Nordisk Way is a set of guiding principles which underpins every decision we make. We use a unique, systematic approach known as facilitation to ensure that everyone lives up to the Novo Nordisk Way. Any issues identified during a facilitation are addressed locally, and consolidated insights are shared with Executive Management and the Board of Directors. The Novo Nordisk Way also underpins our performance management and incentive programmes.


In 2020, a total of 26 units were facilitated and more than 1,200 employees, were individually interviewed. In addition, feedback on those units was collected from approximately 340 stakeholders. Overall, the 2020 process continues to show a good level of adherence to the Novo Nordisk Way. Three units were found to be in breach of one or more of the Novo Nordisk Essentials. The Essential with the strongest performance continues to be the 'Patient-centred business approach'. In 2020, partly driven by the focus on strengthening the culture journey, significantly more findings were issued related to the Essential 'We set ambitious goals and strive for excellence'. 

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:

Our other declarations, disclosures and statements include: 

  • California Transparency in the Supply Chain Act 

For our declaration on the California Transparency in the Supply Chain Act, visit our US website.

  • Conflict Minerals Disclosure  

Read our Conflict Minerals Disclosure 

  • UK Modern Slavery Act 

Read our statement on the UK Modern Slavery Act


The number of supplier audits concluded in 2020 decreased by 25% compared with 2019. The decrease was due to COVID-19-related restrictions imposed on travel and general ability to access suppliers' facilities and subsequent postponement of planned audits. No critical findings were issued related to responsible sourcing audits of which 7 were conducted in 2020 compared with 27 in 2019, while one critical finding was issued related to a quality audits regarding handling of controlled waste In 2020, 170 quality audits were conducted compared with 236 in 2019. A follow-up audit has since been conducted, where the critical finding was found to have been closed satisfactorily.

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.

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.

Counterfeit products

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.


Novo Nordisk had no product recalls from the market in 2020, compared with four in 2019. To verify that the product recall process remains robust and efficient, a mock recall was effectuated in 18 affiliates worldwide. Based on that, the product recall process has been evaluated and concluded to be effective.

In 2020, as in 2019, there were no failed inspections among those resolved at year-end. During the year, 77 inspections were conducted, compared with 66 in 2019. At year-end, 59 inspections were passed and 18 were unresolved, as final inspection reports had not been received or the final authority acceptance was pending, which is normal. Follow-up on unresolved inspections continues in 2021.

As a leading global healthcare company, we engage with a variety of stakeholders, including public officials, healthcare professionals, patient organisations and business partners. In all our interactions, our first priority is to live up to our responsibilities and all regulatory requirements.

Our policy on transparency is clear - we will be transparent and accountable for how we operate and the transactions that take place when and where we work.

This is a part of Novo Nordisk’s company values expressed in the Novo Nordisk Way and  in our Business Ethics Compliance Framework, and how we earn and retain trust and confidence.

The level of trust in Novo Nordisk among key stakeholders – people with diabetes, general practitioners and diabetes specialists – is an indicator of the extent to which we are living up to stakeholders’ expectations.


Our trust score, measured on a scale of 0-100, increased to 80.6 in 2020 from 78.2 in 2019. The increase was the most significant improvement in a trust score in the pharmaceutical industry in 2020.


We are committed to being a sustainable business. To achieve this ambition, we do business in a financially, environmentally and socially responsible way (the Triple bottom line), always keeping in mind what is best in the long term for the patients we serve, our shareholders, our employees, the communities in which we are present and the global society we are part of.

Our overall guiding principle within tax is to have ‘a sustainable tax approach’, emphasising our business anchored approach to managing the impact of taxes while remaining true to the Novo Nordisk values of operating our business in a responsible and transparent manner.

Novo Nordisk is 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 agreement1. The remaining residual profit is subsequently allocated to the principals.

The Board of Directors approves the Novo Nordisk tax policy annually and the Audit Committee monitors key tax risks on an ongoing basis.

Business anchored tax approach
Novo Nordisk’s legal and business structures are based on business anchored considerations and business substance. Consequently, we pay taxes where value is generated. This means that taxes are a consequence of business anchored considerations while always respecting international and domestic tax rules. 

Being a global company means that we also do business in low-tax jurisdictions if there is a local demand for our products. In some jurisdictions where we operate, tax incentives are offered, and our tax approach does not prevent us from making use of such incentives in so far as our activities are business-driven 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 advance pricing agreements in many of our key markets. Putting in place advance pricing agreements 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 advance pricing agreements, we engage in dialogue with tax authorities on for example binding rulings and new legislative initiatives to ensure common understanding.

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.

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.

Tax transparency and governance
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 dialogue.

Tax risks are monitored, and adequate controls enforced globally through standard tax governance systems and risk reporting and monitoring tools with regular reporting to the Audit Committee and the Board of Directors. Tax risks are managed by our global tax organisation ensuring timely involvement of qualified specialists. 

The landscape for environmental, social and governance (ESG) reporting frameworks is rapidly developing, and we will continuously assess which framework(s) are most suitable for Novo Nordisk to report against.

We report on the Stakeholder Capitalism Metrics published by the World Economic Forum, and thus report on our total tax contribution in accordance with this standard. Furthermore, we share insights in the annual report on our tax policy and our corporate taxes paid on a region-by-region basis in line with our segmented business reporting dimensions.

Approved by the Board of Directors of Novo Nordisk A/S | 4  August 2021

1Advance pricing agreements are ahead-of-time agreements between tax authorities in two or more countries, determining the appropriate intra-group pricing for certain transactions for a predetermined amount of time.

The total tax contribution in 2020 amounted to DKK 26,376 million split with 52% on taxes borne and 48% on taxes collected. In 2019, the split was 54% on taxes borne (DKK 14,829 million) and 46% on taxes collected (DKK 12,698 million).

The overall decrease in total tax contribution from 2019 to 2020 is primarily related to 'Corporate income taxes paid'. This is mainly due to less prepayment in Denmark as a consequence of acquisitions in the end of 2020.


We aim to have zero environmental impact across our value chain. This work is organised across the company and in our environmental management system.

Our Executive Management is responsible for the overall environmental policy and for setting strategic direction for environmental areas. Our Corporate Environmental Strategy team is responsible for the environmental policy and strategy. In addition, there is a dedicated department, NN Environment, which is responsible for the environmental management system and ensuring environmental compliance in Novo Nordisk.

All our production facilities are certified according to ISO 14001, environmental management. The ISO 14001 certified Environmental Management system ensures continuous improvements through a systematic approach. The production of active pharmaceutical ingredients (API) in Kalundborg, Denmark, is also certified according to ISO 50001, energy management.

We have on-site Environmental coordinators at all production facilities. The coordinators monitor environmental progress and environmental compliance at our sites worldwide.

For information about our Circular for Zero strategy, click here.

For information about our environmental policy, click here.


In 2020, there were 15 breaches, a decrease from 16 breaches in 2019. The breaches were mainly related to wastewater, and all had a minor impact on the environment.