From a business perspective, demonstrating adherence to corporate values and communicating consistent messages is one way to earn trust and win stakeholders’ confidence. For Novo Nordisk it is also an opportunities-driven approach that drives performance and sparks innovation across the value chain.
The Novo Nordisk Vision guides people in the company not only in terms of what to aspire for, but also how to conduct business responsibly. The company’s commitment to contribute to sustainable development spells out the objectives to make decisions in a way that balances compassion and competitiveness, the short and the long term, self and commitment to colleagues and society, work and family life. Through engagements with stakeholders, Novo Nordisk seeks to achieve sustainable solutions to shared goals and draws valuable insights on stakeholder attitudes, wishes and needs.
As part of these efforts, Novo Nordisk’s Business Ethics Programme aims at enabling all employees to always attach weight to ethical considerations when making business decisions.
Novo Nordisk’s Business Ethics programme includes compliance with legislation and offers guidance on individual judgements. The Business Ethics Policy sets direction and states that bribery and corruption are unacceptable. It is backed by a number of procedures for ethical business conduct, promotion and relations to Health Care Professionals and contracting with agents and other third parties.
Novo Nordisk seeks to involve with external partners to constantly develop in the area of Business Ethics and avoid complacency. Thus, in 2008 the University of Copenhagen, UNESCO and Novo Nordisk launched a ground-breaking collaboration to develop publicly available tools for ethical decision making both in the area of Business Ethics and the area of Bioethics. Further, Novo Nordisk gave Ph.D. student Leila Trapp, the University of Aalborg, the opportunity to conduct a comparative study of Business Ethics communications across geography and cultures.
Strengthening the organisation
In 2008, Novo Nordisk established a Business Ethics Compliance office in Headquarters to globally support and monitor the company’s Business Ethics Policy and Procedures and manage training covering anticorruption, conflicts of interest, promotion of pharmaceutical products, and interaction with healthcare professionals, suppliers and intermediaries.
The procedures that govern Novo Nordisk’s Business Ethics Compliance programme were updated in 2008, clarifying requirements for documentation, completely banning so-called facilitation payments (very small payments to facilitate processes) and including a provision to ensure that the company’s public affairs work is completely transparent, is consistent with its values and in compliance with legal requirements.
Training and information tools in the form of e-learning, an offline train-the-trainers toolkit, and a revised booklet were prepared in 2008 for launch in 2009.
All managers have been trained in business ethics, and all line of business sales and marketing employees were trained in 2008, as they have to undertake annual training.
Compliance is assured by Group Internal Audit, which conducts reviews of business units worldwide.
Further, the Business Ethics website launched in 2007 was updated in 2008 now including online answers to frequently asked question thus providing easy-to-access advice for employees. Here, all information relevant to the programme is collected, and employees can easily get information about the procedures, access e-training programmes, download templates for contracts and due diligence questionnaires, find their contact persons, and understand how an investigation is undertaken, including the code of conduct for the investigators,
Measuring programme progress
Also in 2008, the Business Ethics Compliance Programme was anchored in the Balanced Scorecard against, based upon which individual managers’ performance is measured. Business Ethics will continue to be on the Balanced Scorecard in 2009 in the form of training targets and targets for follow-up on to Group Internal Audit observations in the Business Ethics Area.
Monitoring progress and continued development of the programme ensures that it is responsive to the most relevant and pressing concerns as viewed by Novo Nordisk and its stakeholders.
Novo Nordisk’s approach
Novo Nordisk Business Ethics Policy states:
“In Novo Nordisk we will conduct our business according to a high ethical standard, living our values and protecting Novo Nordisk's reputation.
This means that we will:
- Adhere to the principles of the UN Convention against Corruption
- Conduct business with integrity, honesty and professionalism
- Work against bribery in any form.”
The policy is backed by three main procedures:
- Business ethics – dealing with conflicts of interest, bribery, facilitation payments, donations, gifts, commission fees for local distributors, and interaction with suppliers,
- Interaction with Health Care Professionals – covering promotion of pharmaceuticals and standards for ethical interaction with public officials and healthcare professionals,
- Novo Nordisk contracts with marketing consultants, agents etc. - concerning legal compliance, due diligence and audits, contracts and fees for services, deliverables and payments, and accounting, documentation and deviations, which in turn are supported by a third tier of procedures covering e.g. standards for off-label information, data privacy, etc.
The policy and procedures are endorsed by the Executive Management and the Board of Directors of Novo Nordisk.