Enforcing integrity standards
We ensure our standards of ethical business conduct are put into practice by handling complaints, monitoring activities and reporting results.
Handling complaints
Novartis supports an open culture in which employees are required to report violations of our Code of Conduct and are protected from retaliation or penalties.
The Business Practices Office (BPO) provides a formal system for dealing with complaints of actual or suspected cases of misconduct. The BPO offers employees and external stakeholders a trusted channel to report misconduct without fear of reprisal or penalty. All complaints are investigated, and substantiated cases are escalated to management for appropriate action.
During 2011, the BPO received 1 522 complaints that became investigations, with 825 of these substantiated and 384 dismissals and resignations related to misconduct. The majority of cases investigated by the BPO involved fraud, such as fraudulent expense reporting.
The Business Practices Officer can be contacted at:
Monitoring
Monitoring helps ensure integrity standards are effectively implemented. Local managers are responsible for applying of key policies and standards, including the Novartis Pharma Principles and Practices for Professionals (NP4) Policy and Guidelines.
These activities are supported by Internal Audit and third party external assurance, which monitor the establishment of management processes and adherence to integrity standards.
The Enterprise Risk Management function within Novartis periodically assesses risks stemming from noncompliance with our standards, and helps monitor implementation of our policies and values. We regularly benchmark our overall integrity and compliance program against other companies.
