Ethics Transparency

Ethics & Transparency

Office of Ethics

Office of Ethics
Ethics & Transparency

How we operate is as important as what we do.

It is critically important to our patients, consumers, purchasers, health care professionals, employees and investors, and to the sustainability of our business success, that we adhere to all applicable laws and regulations, follow ethical business practices, maintain good corporate governance and treat people with respect.

We have strong management oversight, comprehensive corporate policies and procedures, and a long history of abiding by legal and regulatory requirements and promoting high ethical standards. Every employee worldwide is responsible for adhering to business practices that are in accordance with the letter and spirit of the law and with ethical principles that reflect the highest standards of corporate and individual behavior.

Our company’s Office of Ethics was established over 20 years ago to protect and promote the company’s values and standards on a worldwide basis by developing and overseeing global initiatives designed to deter illegal, unethical and improper behavior related to the company’s business. It is responsible for ensuring that employees are aware of and trained on the Code of Conduct and corporate policies.

Resources for Employees

The Office of Ethics serves as a channel for the receipt and investigation of employee ethical and compliance-related concerns. There are multiple vehicles through which employees can contact the Office of Ethics. Employees can contact the Office of Ethics directly, by a toll-free telephone number or by email, to speak to an ethics officer or ombudsperson. Our company also provides a confidential, toll-free intake service, called AdviceLine, through a third party that offers the option for the reporting person to remain anonymous.

The Office of Ethics is also responsible for managing our Ombuds Program, which offers an additional safe haven for U.S.-based employees to discuss work-related issues without fear of retaliation. This program confidentially addresses employees’ concerns mainly relating to manager or coworker relations or fair treatment. In 2015, 43 percent of the calls that the Office of Ethics received were classified as part of the ombuds process.

Addressing Misconduct

It is our policy to maintain a work environment where all employees are expected to report ethical and compliance concerns that are potentially inconsistent with the company’s Code of Conduct and policies. Our company is committed to maintaining a process that ensures timely escalation and investigation of potential- and compliance-related concerns.

Retaliation against employees who report such concerns is a violation of corporate policy and will not be tolerated. The Office of Ethics is responsible for oversight of the global processes for managing investigations into potential ethics and compliance concerns to ensure consistent and timely resolution of potential concerns and implementation of remediation actions. When we substantiate allegations of ethical misconduct, we take appropriate disciplinary actions in order to ensure that those who were responsible are held accountable. Disciplinary actions can include dismissal from the company, issuance of final written warning letters or financial penalties. We also take appropriate steps to address any needed improvements in organizational and process controls.

We also maintain a policy that will give our company the discretion to recoup incentive payments made to employees in certain instances. This policy will apply when a senior leader engages in misconduct or fails to reasonably supervise an employee who engages in misconduct that results in a material policy violation relating to the research, development, manufacturing, sales or marketing of company products where the policy violation causes significant financial or reputational harm to the company.

Annual Ethics & Policy Certification

An important component of our corporate compliance program is our annual ethics and policy certification. The annual review process requires selected company employees to certify compliance with corporate policies on ethical business practices, antitrust-law compliance, and conflict-of-interest and insider trading. These employees are also expected to regulate their outside activities to avoid any conflicts of interest and certify, in writing, whether actual or potential conflicts of interest exist. Where potential conflicts are identified, the Office of Ethics will work with management to take actions to mitigate the potential conflict. In addition, all U.S.-based employees must certify compliance with our corporate policy on the effects of exclusions, debarments, suspensions and health care-related criminal convictions, reporting and screening.

Code of Conduct

Our Code of Conduct, Our Values and Standards, is considered to be the foundation of our company’s success. These values and standards apply worldwide, wherever our company does business.

Our Code of Conduct, available in 26 languages, applies one standard of conduct to all employees worldwide.

The values and standards embodied in our Code of Conduct are designed to promote ethical business practices in a continuously evolving business environment and to deter employee misconduct. The core values included in the Code of Conduct are intended to foster:

  • Compliance with company policies and applicable governmental laws, rules and regulatory requirements
  • Safeguards to protect the privacy of personal information, as well as honesty and transparency in communications about our products
  • Measures to mitigate potential conflicts of interest
  • Prompt internal reporting of potential violations of the Code of Conduct and policies
  • Employee accountability for adherence to the values and standards set forth in the Code of Conduct

Ethics Training & Development

We provide training to all employees worldwide on our Code of Conduct to ensure awareness of our values and standards, as well as of a variety of associated topics such as privacy and the prevention of discrimination, human rights, harassment, corruption and bribery. Ethics and compliance content is also integrated into business and leadership development courses for managers and senior leaders on an ongoing basis. Ethics and integrity are key leadership competencies that are assessed as part of annual performance reviews and play an integral role in our decisions about employee advancement within the company.

External Suppliers’ Ethical Standards

We abide by strict ethical standards in our own operations—and we insist on equivalent standards from our suppliers. Our Business Partner Code of Conduct is based on our own Code of Conduct, as well as on the Pharmaceutical Supply Chain Initiative’s (PSCI’s) Pharmaceutical Industry Principles and the Ten Principles of the UN Global Compact.

Learn more about how we work with our suppliers to uphold ethical standards.

Ethical Business Practices
Employees trained on the Code of Conduct90%92%99%99%99%
Employees who have taken the annual Code of Conduct refresher courseNANA99%99%99%
Employees who responded to disclosure statement on Conflicts of Interest form98%99%NA100%100%
Concerns brought to the company’s attention, such as employees seeking ombuds services (most often relating to manager or coworker relations) and guidance on conflict of interest or Code of Conduct issues873713624517484
Allegations involving noncompliance with company policy investigated1,0801,0129681,069638
Ratio of substantiated allegations to concerns/issues raised65%60%58%60%58%
Employees separated related to substantiated corporate policy violations1NA166313365156
Employees who received written warnings as disciplinary actions resulting from a substantiated concern2NA232269323148
Worldwide employees represented by an independent trade union or covered by a collective bargaining agreement30%31%32%31%32%
NA: Not available.
1 This data represents investigations conducted on a companywide basis.
2 Prior to 2012, this data was not tracked on a global basis.