Along
with economi-cally, socially and environmentally responsible behavior, high ethical
standards are essential to the business of Novartis. We
strive to maintain and to strengthen a culture where associates recognize that
acting honestly, lawfully and with integrity is a key to success – as well as
the right thing to do. The ideals and values which
Novartis expects associates to uphold are defined in the Code of Conduct, and
the Policy on Corporate Citizenship with its related policies and guidelines.
“By ensuring compliance with the Code of Conduct and our Corporate Citizenship
Policy, we are better able to earn the trust of the company's stakeholders and
of the public at large,” says Urs Baerlocher, Head of Legal and General Affairs
of the Novartis Group and Member of the Group Executive Committee (ECN).
NEW FRAMEWORK Amendments of the US Sentencing Guidelines
in 2004 gave added impetus to compliance programs at major international companies
around the world. Although Novartis companies were already meeting most, if not
all, of these requirements, Novartis leveraged the Amendments in further driving
its Compliance program. |
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example, the Compliance Steering Committee established a new framework for the
company’s Ethics Compliance program last year, meeting requirements of the Sentencing
guidelines. This new framework is being implemented by local Novartis entities
worldwide and will be used to set Ethics Compliance objectives for 2006.
At Novartis, line management bears ultimate responsibility to maintain and improve
Ethics Compliance, which is viewed as an embedded management process, included
a-mong managers’ annual performance objectives. Line
managers are supported by the Group Ethics Compliance Officer – as well as counterparts
at each Division. In addition, roughly 180 part-time compliance officers pro-vide
support to local management in 72 countries and more than 270 Novartis operating
units around the world. This structure ensures a global perspective while still
taking advantage of local expertise on Ethics Compliance issues.
CODES, POLICIES AND STANDARDS The Novartis Code of
Conduct sets out our standards of ethical behavior. On the basis of the Code of
Conduct, detailed policies and standards have been established for specific activities,
such as marketing. Marketing Codes have been put
in place by the Pharmaceuticals and Sandoz Divisions, as well as for each Business
Unit of the Novartis Consumer Health Division. The
Novartis Purchasing Depart-ment has been working on the implementation of our
“Third-Party Management” guideline, requiring that our main business partners |
| partners
also apply a minimum set of ethical business standards in their organizations.
Demonstrating high ethical standards is particularly important at the management
level. Managers and insiders are expected to support and to encourage their staff
to comply with our high ethical standards. As part of a formal certification process,
more than 20 000 Novartis managers and insiders confirmed, in writing, their adherence
to company policies and standards during 2005.
TRAINING AND COMMUNICATION In recent years, Novartis
has intensified training programs for associates and compliance e-learning. In
2005, Novartis associates worldwide completed more than 197 000 e-learning courses
– investing more than 148 000 hours in Ethics Compliance e-training. In parallel,
several thousand associates without access to e-mail completed other forms of
Ethics Compliance training. Ethics Compliance e-learning
at Novartis is available in 14 languages – setting a high standard among global
companies. A survey con-ducted last year showed that 96% of Novartis associates
in the US participated in Ethics Compliance training during 2005. Of those participants,
97% said the courses were “effective” or “very effective”. Courses
on the Code of Conduct, Corporate Citizenship or Conflict of Interest Policies
are mandatory for all employees around the world. If employees do not have e-mail
access, Novartis provides other training methods to offer the possibility to complete
these courses. |
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