We believe that ethical conduct results from a culture of integrity. Ours is built around a Code of Conduct, which is a fundamental part of the terms of employment for all associates of Novartis Group companies.
The Code contains our principles and expectations for ethical business conduct. This is important because our associates may encounter ethical dilemmas during the course of their work. The Code guides associates in their behavior and helps them to make the right decisions when they face difficult situations.
The values including integrity and courage that build the foundation for our ethical culture underpin our management processes, including the annual performance reviews of associates, to encourage and reward ethical behavior.
The Global Integrity & Compliance (I&C) function designs and implements compliance programs associated with the Novartis Code of Conduct, Anti-Bribery Policy, Professional Practices Policies, and Conflicts of Interest Policy. Each Novartis division has a Global I&C Officer who drives the implementation of these programs, with the goal of ensuring ethical business practices by all associates.
Ensuring ethical and lawful outcomes starts with clearly defining and articulating our expectations towards the ethical behavior of our associates, embodied in our Code of Conduct.
The five core principles in the Code of Conduct are:
We put patients first. Their needs and safety are at the heart of everything we do
We treat our associates fairly and respectfully
We are committed to outstanding and sustainable performance with integrity
We strive to be a trusted healthcare partner
We aspire to be a good corporate citizen
The Code of Conduct is organized around our commitment to meet the expectations of our five key stakeholder groups: our patients, associates, shareholders, healthcare partners and society at large.
We have written our Code of Conduct in simple, clear language that provides short, practical tools to help associates make decisions when in doubt. The Code clearly states the process for reporting misconduct. All associates receive copies when they join the Novartis Group, along with regular training, which continually emphasizes the importance of adhering to the Code’s principles.
The Code of Conduct has been translated into 18 languages and has been adopted by local boards. All Novartis associates worldwide are held accountable to its contents.
Embedding integrity standards
We embed the five principles of our Code of Conduct in our work in a variety of ways. Most importantly, Novartis expects managers to lead by example. This means that managers must accommodate ethical considerations in business planning and decision making, training associates to ensure they will make responsible decisions, and encouraging associates to speak up when ethical challenges arise.
In addition to the ethical leadership that we expect from our managers, and to skills and awareness training, we encourage and incentivize ethical behavior by including an assessment of each employee’s alignment to our values and behaviors in their annual performance appraisal. Achieving business objectives and alignment with company values receive equal weighting in compensation reviews.
Training and guiding associates
Awareness and training programs are offered in a range of formats, including awareness-building programs, e-training, face-to-face programs, games and workshops. We provide extensive communication toolkits to support awareness programs at the local level and include ethical training in our Corporate Leadership Learning programs. We also provide extensive training for our Integrity and Compliance Officers across the company.
All Novartis Group company associates are required to complete integrity and compliance training. The Compliance e-training curriculum provides relevant information to enable associates to make the right choices in the course of their work and to perform with integrity. It addresses identified and relevant company risks and helps to communicate new and upgraded policies and guidelines across the organization. In 2016, the following courses were available: Code of Conduct, Adverse Events, Anti-Bribery, Data Privacy, Information Management and Social Media.
In addition, all newly hired associates worldwide complete a mandatory onboarding e-Training course called “[email protected]”. This comprehensive course covers 17 subject areas and is sent to all new hires four weeks after their employment begins.
E-Training completion rates
Simply delivering compliance training, electronically or otherwise, is not enough – we want to ensure associates complete the training and are embedding the lessons learned into their daily work.
The completion rates for our 2016 e-training courses were as follows:
Code of Conduct: 98% Social Media: 97% Information Management: 97% Anti-Bribery: 97% Data Privacy: 98% Adverse Events: 97% Target completion rates are 100% for Code of Conduct, 95% for all other courses six months after launch.
Novartis is committed to building and maintaining a culture of integrity. We require associates to report actual or suspected violations of our Code of Conduct, but realize that fear of reprisals can make people hesitant to speak up. This is why we enforce clear policies to prevent retaliation against any associate reporting an issue.
The Business Practices Office (BPO) offers employees and people outside of Novartis a channel through which to report misconduct. Complaints can be made by email or phone via a third-party hotline. The BPO manages investigations into all complaints, and escalates any substantiated cases of misconduct to management for appropriate action.
In 2016, the BPO received a total of 3 595 complaints of alleged misconduct, of which 1 707 were investigated under the BPO process. 1 888 were assessed not to be related to misconduct and were delegated for review and action outside the BPO investigative process; 893 were substantiated, including 401 that resulted in dismissals or resignations. Of these investigated allegations, 46% pertained to fraud, 32% to professional practices and 6% to conflict of interest.