We aspire to be a trusted leader in changing the practice of medicine. To realize this vision, we need to earn and maintain the trust of patients, associates, healthcare partners, shareholders and the society we serve.
We recognize society’s expectations of our industry and of Novartis, and that we must go beyond just doing what is legal in order to meet legitimate expectations of society.
Our aim is to prevent issues from occurring, drive personal accountability for behaviors, and generate learnings that can be applied across the organization. In addition, we maintain a strong commitment to upholding human rights and managing risk in our supply chain. We began this journey some years ago, and we continue to make progress.
In 2014, we created the position of Chief Ethics and Compliance Officer, reporting to the CEO, elevating the Compliance function to the highest levels in the company. On April 1, 2018, we combined our risk management and compliance functions into a single organization called Ethics, Risk and Compliance (ERC), and announced the new role of Chief Ethics, Risk and Compliance Officer, which was further elevated to become a member of the Executive Committee of Novartis.
In 2019, we took further steps to strengthen our governance. The first was integrating Third-Party Risk Management (TPRM). With this move, the collaboration between the TPRM team and the ERC function helps provide greater transparency around one of our key risks: third parties. Because of the elevated human rights risks when dealing with third parties, we merged our human rights and TPRM program into one function named Human Rights & Third Party Risk Management. This will help ensure more effective human rights due diligence in our supply chain and ingrain human rights further into our core business practices and strategies across our markets.
We also created a new function for risk and resilience that brings together the former Risk Office, Risk Assessment and Monitoring, Business Continuity Management and Novartis Emergency Management in order to establish a comprehensive and integrated risk management framework that is coordinated among risk functions and business units. As we reimagine medicine, we need to help ensure that our leaders and employees act appropriately when faced with ethical dilemmas and effectively meet society’s increasingly high expectations.
To further reinforce principles-based thinking and ethical decision-making in our organization and interactions with external stakeholders, we have developed a Novartis Code of Ethics, replacing our Code of Conduct as of September 01, 2020. Building on our Professional Practices Policy, and rooted in behavioral science, the code was co-created by Novartis associates, for Novartis associates. More than 3000 associates shared ideas and insights during an early-stage crowdsourcing, and 1 500 participated in a global engagement to encourage open conversations around ethical dilemmas at Novartis. The code was launched during EthicsWeek 2020 – a week dedicated to global events and activities around the world celebrating ethics.
At Novartis, we hold ourselves to high ethical standards and do not tolerate unethical behavior. We are taking all necessary steps to enable associates to do what’s right and ensure compliance with our Code of Ethics and all applicable laws. At the same time, with more than 110 000 associates, we cannot exclude the possibility of misconduct by individuals. We therefore have extensive measures in place in an effort to ensure that reports of suspected misconduct are investigated thoroughly. Where misconduct is found, we work to take swift and appropriate action.
With a goal of ensuring accountability of local country organizations, our management includes integrity and compliance questions as part of standard business reviews. We work to identify and mitigate risk exposure proactively so it can be reviewed and discussed at a management level.
Our goal is to maintain consistent standards of business practices across Novartis, ultimately enabling us to provide the best possible care for patients globally.
Awareness and training programs are offered regularly 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.
All Novartis Group company associates are required to complete ethics, risk and compliance training. Our global 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 addition, all newly hired associates and contractors worldwide complete a mandatory onboarding e-Training course. This comprehensive course covers key subject areas and is sent to all new hires four weeks after their employment begins.
We report relevant completion rates for annual e-trainings in our Novartis in Society ESG Report. Training on ethical business practices is included in our Corporate Leadership Learning programs, and we provide extensive training for our Ethics, Risk and Compliance Officers across the company.
Our Code of Ethics, created by associates for associates, sets out 22 commitments we make to doing what’s right. Underpinned by four ethical principles – Be Open-minded, Be Accountable, Be Bold, Be Honest – the Code of Ethics replaced our Code of Conduct on September 1 2020.