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. 


Assessing risks

Our processes that help identify and assess risks, track their development and define actions on how to mitigate them include:

  • Internal Business Ethics audits (based on a risk-based audit plan)
  • Business Ethics risk reporting/management (twice a year)
  • External benchmarks/assessments of Novo Nordisk’s Global Business Ethics Compliance Programme
  • Compliance Hotline investigations
  • Input on external investigations, risks and trends from partner law firms
  • Peer benchmarking 


High-risk topics, on which we are currently focusing, as outlined in the Novo Nordisk Business Ethics Code of Conduct, are:

  1. Direct interactions with public officials, healthcare professionals and healthcare organisations, patients and patient organisations
  2. Third party representatives who interact with public officials, healthcare professionals and healthcare organisations 
  3. Off-label communication, that is, the promotion of our products not in accordance with the approved product label


Policies and governance 

All employees in Novo Nordisk are expected to adhere to the company’s policies and guidelines at all times. The 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:

  • 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


Compliance training

The Business Ethics Compliance office drives the development of effective education and training programmes. Training activities for employees include:

  • Corporate certification of procedures for all employees in scope
  • E-learning courses targeting a broad audience
  • Tailored face-to-face training focusing on in-depth and interactive dialogue with key employee groups


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:

  • 2016 (= 99%)
  • 2017 (= 99%) 
  • 2018 (= 99%)
  • 2019 (=99%)


Stakeholder engagement

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. 


Reporting concerns

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.

More about the Compliance hotline  

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. 


Corrective actions

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

More information about our transparency disclosures