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 Novo Nordisk operates in. Giving gifts, for example, is important in many cultures, and Novo Nordisk must remain respectful in Novo Nordisk’s business relationships. At the same time, Novo Nordisk 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 Novo Nordisk’s Business Ethics Policy, not only among people working with Novo Nordisk, but also with anyone with whom the company 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 2007
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) took part.
In 2007, local risk assessments were made globally and subsequently local procedures including both local and global issues were made in each sales area. All business units made sure that all employees within sales and marketing were included in an annual training plan with face to face training on Business Ethics. In 2007, 95% of all employees within sales and marketing were trained this way.
In 2007, a Business Ethics website was launched for employees. Here, all information relevant to the programme is collected, and employees can easily get information about the procedures, take training programmes, download templates for contracts and due diligence questionnaires, see pictures of their contact persons, understand how an investigation is undertaken, including the code of conduct for the investigators, participate in a dilemma game, etc.
 | Furthermore, a booklet: ‘Business and ethics’ has been developed explaining the Business ethics programme for employees in a straightforward manner. |
Addressing dilemmas
The procedures in the Business Ethics Policy explain the global standards of behaviour that people can expect from Novo Nordisk employees. However, Novo Nordisk recognises that, despite clear policies and procedures, there are dilemmas that are important to address openly.
For instance, doctors from under funded 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 GIA Business Ethics Assurance team conducts both announced and unannounced reviews of business units worldwide. In 2007 more than 25 such reviews were conducted, and recommendations resulting from these reviews are followed-up throughout the year. Business ethics is also addressed 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 and financial fraud can be raised anonymously, and with no subsequent disciplinary or retaliatory action towards the whistleblower, to the Board of Directors’ Audit Committee via a whistleblower mechanism. In 2007, 33 concerns regarding business ethics or financial fraud were raised through the whistleblower or other internal reporting functions. From 2008, an improved compliance hotline will be in place where concerns may be raised via telephone or web reporting in nine languages, including Danish, English, Spanish, French, German, Italian, Russian, Chinese and Japanese.
Measuring progress
Also in 2007, the business ethics programme was anchored within the Balanced Scorecard against which individual managers’ performance is assessed annually. Business Ethics will continue to be on the Balanced Scorecard in 2008 including e.g. training targets and follow-up related to GIA Business Ethics observations.
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:
1. Business ethics – dealing with conflicts of interest, bribery, facilitation payments, donations, gifts, commission fees for local distributors, and interaction with suppliers.
2. Promotion of pharmaceutical products – covering interaction with public officials and healthcare professionals.
3. 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 reviewed by PricewaterhouseCoopers as part of its assurance of Novo Nordisk’s non-financial reporting. Please refer to Audit and assurance for a full description of the conclusions and the nature of assurance offered.
