Business ethics
Each day, Novo Nordisk employees bring ethical standards to work. Doing business globally entails many challenges, particularly when working in diverse cultures where appropriate business conduct can vary widely. Making the right choices becomes more complex – and more important – in the pressures of a competitive business environment.
It is vital to understand and respect the local customs and practices of the countries we operate in. Giving gifts, for example, is important in many cultures, and we must remain respectful in our business relationships. At the same time, we must never compromise personal integrity and the principles that guide Novo Nordisk’s way of doing business. That makes it all the more important to be clear on our Business Ethics Policy, not only among people working with Novo Nordisk, but also with anyone with whom we do business.
Ethical business conduct is about values and integrity as well as compliance and risk mitigation. Taking a proactive approach also presents opportunities such as enhanced trust in the company and improved relationships with customers and other key stakeholders.
Performance 2006
Novo Nordisk’s Business Ethics programme includes compliance with legislation and offers guidance on individual judgements. The Business Ethics Policy sets direction and states that bribery and corruption are unacceptable. It is backed by three procedures for ethical business conduct, product promotion and contracting with agents and other third parties.
Passing the ethical test
The company's President and CEO, Lars Rebien Sørensen, the Executive Management team and the members of the Senior Management Board attended training workshops during 2006, as did all line managers within procurement and sales and marketing – a total of 297 individuals representing 79 countries. The aim was to provide guidance on how to live up to the Business Ethics Policy, which was introduced in 2005. In addition, all Novo Nordisk's managers and relevant employees in their units have completed an e-learning module on business ethics. This programme is now also a mandatory part of the new managers training. Any employee may complete the e-learning programme, and during 2006 nearly 2,700 employees (close to 10% of the total workforce) did.
The procedures in the Business Ethics Policy explain the global standards of behaviour that people can expect from us. However, we recognise that, despite clear policies and procedures, there are dilemmas that it is important to address openly.
Furthermore, a booklet: ‘Business and ethics’
has been developed to support the internal training.
Addressing dilemmas
For instance, doctors from underfunded hospitals or clinics, particularly in emerging or developing countries, sometimes request donations of funds, equipment or medicine from pharmaceutical companies. From the doctor’s point of view, the company has the financial ability, expertise and social obligation to contribute. The company also sees an obvious need and has a desire to help. If a donation is made, it must adhere to the company's ethical standards. It must not lead to undue advantage or benefit for the company such as inclusion in a list of the hospital’s preferred suppliers. Novo Nordisk’s policy clearly states that managers and employees must be careful to ensure that charitable contributions and sponsorships do not constitute bribery. If the policy is not adhered to, the consequence can ultimately be job termination.
Audit and whistleblower
Group Internal Audit oversees compliance with the Business Ethics Policy and procedures. The audit team conducts both announced and unannounced reviews of business units worldwide. In 2006 more than 25 such reviews were conducted, and recommendations resulting from these audits will be followed up in 2007. Business ethics is also included in regular facilitations that serve as audits of adherence to the Novo Nordisk Way of Management, including company policies.
Concerns over possible breaches of ethical business conduct can be raised anonymously via a whistleblower mechanism via the Board of Directors’ Audit Committee anonymously and with no subsequent disciplinary or retaliatory action towards the whistleblower. In 2006, 12 concerns were raised through the whistleblower reporting system.
Measuring progress
Also in 2007, the business ethics programme will be anchored within the Corporate Balanced Scorecard against which individual managers’ performance is assessed annually. All country managers are evaluated based on their ability to undertake local risk assessment, develop a local procedure on business ethics and ensure continued training for all relevant employees.
Monitoring progress and continued development of the programme ensures that it is responsive to the most relevant and pressing concerns as viewed by Novo Nordisk and its stakeholders.
Novo Nordisk’s approach
Novo Nordisk Business Ethics Policy states:
“In Novo Nordisk we will conduct our business according to a high ethical standard, living our values and protecting Novo Nordisk's reputation.
This means that we will:
- Adhere to the principles of the UN Convention against Corruption
- Conduct business with integrity, honesty and professionalism
- Work against bribery in any form.
The policy is backed by three procedures:
- Business ethics – dealing with conflicts of interest, bribery, facilitation payments, donations, gifts, commission fees for local distributors, and interaction with suppliers.
- Promotion of pharmaceutical products – covering interaction with public officials and healthcare professionals.
- Novo Nordisk contracts with marketing consultants, agents etc concerning legal compliance, due diligence and audits, contracts and fees for services, deliverables and payments, and accounting, documentation and deviations.
The procedures make clear how Novo Nordisk employees should act to preserve ethical standards. This includes a prohibition on political contributions and limitations on entertainment of customers. It also states that employees can never offer anything of value to a public official for the purpose of obtaining an improper benefit for Novo Nordisk. Offering compensation to healthcare professionals for time spent simply attending symposia or congresses is also not allowed.
The policy and procedures are endorsed by the Executive Management and the Board of Directors of Novo Nordisk.
This page has been assessed by PricewaterhouseCoopers as part of its assessment of Novo Nordisk’s statement that it reports ‘in accordance’ with GRI. Please refer to Audit and assurance for a full description of the nature of assurance offered.
