CORPORATE CITIZENSHIP

COMPLIANCE

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ber 2003 by the International Auditing and Assurance Standards Board (IAASB).
We planned and performed our evidencegathering procedures to obtain a basis for our conclusions in accordance to the International Standard on Assurance Engagements (ISAE) 3000 “Assurance Engage-ments other than Audits or Reviews of Historical Information”, approved December 2003 by the IAASB. However, we have not performed an audit according to International Standards on Auditing. Accordingly, we do not express such an opinion.

The scope of our evidence-gathering procedures was to:

Observe the existence of internal management processes which ensure the implementation of the CC Policy, the Code of Conduct, the Business Practice Office (BPO) misconduct reporting, the Third Party Management (3PM) initiative and the marketing practices across the Group;
Test the effectiveness of the internal reporting system used to collect HSE information from Group subsidiaries;
Observe compliance with the Group internal HSE reporting guidelines at selected sites; and
Perform, on a sample basis, certain procedures on the 2005 CC and HSE key figures.

Our evidence-gathering procedures included the following work:

Interviewing personnel respon-sible for CC management at Group level;
Visiting the Pharma, Sandoz, Consumer Health and Ciba Vision business unit global headquarters, selected country

 and business unit headquarters and specific sites in Argentina, India, Switzerland, Turkey, the United Kingdom and the United States;
Interviewing the personnel responsible for CC management, including CC reporting and key figures, Code of Conduct training, the 3PM imple-mentation, the Compliance reporting, and marketing practices in the different headquarters where our visits took place;
Performing tests on a sample basis of evidence supporting selected HSE parameters with regard to the reported data aggregation from the selected sites to Group level; and
Reading and performing tests on a sample basis of the relevant documentation including Group policies, management and re-porting structures, documen-tation and systems in place to collect, analyze and aggregate reported CC and HSE key figures.

In our opinion and based both on our work described in this Report and the principles detailed in paragraph 2 of this Assurance Report, nothing has come to our attention that causes us not to believe that:

The Group level internal management processes intended to implement the CC policy, the Code of Conduct, the BPO misconduct reporting, the 3PM initiative and the marketing practices are functioning as designed;
The internal reporting system for the collection, analysis and aggregation of the reported HSE key figures is functioning as designed;
The Group internal HSE reporting guidelines have been applied properly; or
The reported 2005 CC and HSE key figures

 figures from the sites and reporting units do give, in all material respects, a fair picture of the CC and HSE performance.

From our work, we have provided the following recommendations to the management, which have been agreed:

Consider clarifying, simplifying and streamlining the CC organization: reasses the value and purpose of having numerous CC related roles and evaluate the need for more focused CC leadership at key levels within the organization.
Clearly define the definitions of the questions and terms used in the CC reporting and realize a focused communication to the reporting units to ensure a clear and consistent understanding.
Strengthen the HSE reporting control environment at site level through the application of existing tools that facilitate plausibility checks, cross-checks and trend analyses and ensure that site level HSE reporting procedures and controls are adequately documented.

PricewaterhouseCoopers AG


Dr. Thomas Scheiwiller


Thomas Frei

Basel, January 18, 2006

 

NOVARTIS GROUP BUSINESS REVIEW 2005