In
addition, training courses in areas such as Competition Law and Insider Trading
are mandatory for associates working within certain functions. In 2006 Novartis
will launch additional training courses on topics such as Human Rights and Sales/Marketing.
Last year, a new Corporate Ethics intranet site was launched to assist associates
in understanding the Group’s commitment to high ethical standards and to provide
them with practical help, such as publishing examples of inappropriate behavior,
updated on a regular basis. The intranet site also is a valuable training tool
for Ethics Compliance Officers throughout the Novartis organization.
The emphasis on training under-scores a key objective of the Ethics Compliance
program. All companies in the Group must exercise due diligence to prevent and
detect criminal conduct – but self-regulation by associates, facilitated through
appropriate management procedures, is the most effective deterrent.
Through our Ethics Compliance program we attempt to ensure that associates not
only read about their obligations, but also understand what is expected of them,
depending on the role each individual associate performs. We encourage associates
to think before acting and in cases of uncertainty, to seek clarification, addressing
any concerns.
INQUIRIES & COMPLAINTS
A new Business Practices Office (BPO) was established during 2005 to facilitate
reporting by employees of actual or suspected |
| cases
of internal misconduct. All employees are requested to report suspected misconduct
to the BPO, which in turn ensures that all complaints are properly inves-tigated,
enabling management to take appropriate actions. The
Business Practices Officer re-ports monthly to senior management on allegations
of misconduct received, sanctions applied and lessons learned. All cases of financial
fraud, however, are reported to a committee led by the Chairman and Chief Executive
Officer on a monthly basis. The identities of Novartis
employ-ees are fully protected both when they make a report and during any subsequent
investigation. Novartis has a strict policy guaranteeing non-retaliation against
associates who make reports under the “whistleblower” policy – and violations
of this right are not tolerated. During 2006, a global
network of telephone help lines will be rolled out to allow all associates to
report incidents of misconduct locally, in their native language, on a confidential
basis.
VIOLATIONS
AND REMEDIAL ACTION From April to December 2005, Novartis
received reports of 442 alleged violations of our internal rules, such as the
Code of Conduct and Marketing Codes. Of these cases, 228 have been fully investigated
and closed, resulting in 142 cases being fully or partly substantiated. Employment
con-tracts of 78 associates were discontinued and other relevant sanctions were
taken against 64 employees. Novartis intends to publish
annual data on misconduct and sanctions in the future. |
| Last
year, two Novartis Consumer Health NCH) affiliates in the US settled potential
claims against them arising from an investigation of the enteral pump industry
by the US Department of Justice. DATA-PRIVACY PROTECTION
Data privacy involves the protection of personally
identifiable infor-mation about individuals, such as their health information,
em-ployment and financial information, and the companies with which they choose
to do business. New, complex privacy laws now exist in many areas of the world,
and the landscape continues to evolve rapidly in response to factors such as advances
in technology, electronic communications, Internet use and security.
Novartis appointed a Data Privacy Officer in the US in 2003. The following year,
the Global Privacy Office was established as a new department to address internal
com-pliance and the external landscape. The Global Privacy Office is also charged
with creating a corporate culture that respects privacy and fosters trust both
within the company and with regard to its external customers and vendors.
Many country organizations in the Group have appointed a privacy officer and numerous
employees assist with privacy matters in countries such as Japan and those of
the EU, where data privacy laws are particularly stringent. The US organization
has cross-functional privacy teams as well as depart-ment-level privacy nominees
who coordinate with the Privacy Office. Significant progress has been made in
achieving our data privacy goals. |
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