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 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.
Our processes that help identify and assess risks, track their development and define actions on how to mitigate them include:
High-risk situations, on which we are currently focusing, as outlined in the Novo Nordisk Business Ethics Code of Conduct, are:
All employees in Novo Nordisk are expected to adhere to the company’s policies and guidelines at all times. The Business Ethics Compliance Officer/Chief Compliance Officer is in charge of implementing the corporate Business Ethics standards.
The Business Ethics Committee is responsible for developing and implementing the Global Business Ethics strategy, ensuring the ongoing development of the Global Business Ethics Compliance programme and monitoring business ethics at Novo Nordisk. Executive Management and the Audit Committee oversee the Global Business Ethics strategy.
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:
An annual external review ensures that the programme is improved where needed. Recent improvements include:
The Business Ethics Compliance office drives the development of effective education and training programmes. Training activities for employees include:
Business Ethics training is integrated into all onboarding programmes for new employees and in management development programmes. All employees in scope have to pass an annual test to ensure that our corporate procedures have been both read and understood. We document all compliance-related training activities in our global learning and management system.
Employee online testing monitors the effectiveness of compliance training.
The percentage of Novo Nordisk employees who have certified the Business Ethics Code of Conduct and passed the related tests on the global Business Ethics requirements is as follows:
We engage with external stakeholders to exchange knowledge and challenge our Global Business Ethics Compliance programme.
Internally, engagement programmes include interactive dialogue with key employee groups.
We are committed to preventing and correcting unlawful and unethical behaviour. Since 2004, our Compliance Hotline (our whistle-blower function), has been used to anonymously raise any concerns about potential or actual breaches of regulations or internal policies. The Compliance Hotline is available online or via phone and is translated into over 40 languages.
In addition, all employees are required to report suspected misconduct within financial fraud, quality issues, the Novo Nordisk Way and business ethics to the Audit Committee Secretariat through internal reporting lines.
We conduct internal audits to assess compliance to our Business Ethics Code of Conduct and the requirements set forth in our Business Ethics Framework. During on-site visits, auditors interview local management, employees and/or third parties to assess knowledge and implementation of our business ethics procedures.
We also use internal facilitators (value audits), conducted by a senior team with an in-depth understanding of our business and environment, to ensure our business ethics are upheld.
We have global guidelines for assessing misconduct. Independent and objective investigations are carried out for all cases, including those identified internally. This approach is designed to give employees full anonymity and confidence in reporting concerns. Investigations in all regions are performed in accordance with a global compliance investigation manual. All substantiated cases are thoroughly assessed and, depending on the severity, a disciplinary sanction is applied ranging from counselling/retraining to a verbal warning, or in severe cases dismissal in accordance with our internal guidelines.
All significant cases are communicated to the Audit Committee.
Private sector contributions to public policy processes can create the risk of corruption. All our interactions with public officials are governed by Novo Nordisk’s Business Ethics Code of Conduct.
For transparency and disclosure of contributions, we established a system to ensure compliance with all local and regional requirements worldwide, including the US Sunshine Payments Act, the French Loi Bertrand Act, the EFPIA Disclosure Code, and the European Commission and European Parliament transparency registry. For a full list of Novo Nordisk PAC political contributions in the US, please click here.