Business Ethics

There is not one single definition of what business ethics is and for different companies it might mean different things. For Novo Nordisk - Business ethics is about how we think and how we act in the market place. It is about making decisions in our day to day work that we feel are right for the company and for us as individuals. It is also about ensuring that the company’s business ethics standard operating procedures and guidance are adhered to.

Basically, the aim of our business ethics efforts is to provide a clear picture of what is acceptable and unacceptable behaviour.

Standards of conduct

The business ethics policy is an integrated part of The Novo Nordisk Way, and is implemented through three standard operating procedures. The procedures, which were revised in 2008, lay down minimum global requirements, and have been binding for staff since December 2005.

The three procedures that back the policy are:

  • 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.

Training and support

The business ethics standards are communicated to staff and guidance is provided in various forms. The training, which include e-learning, workshops, train-the-trainer workshops, is seen as very important tools guiding the employees.

For more performance related information see our latest annual report

Assurance

It is important for Novo Nordisk to mechanisms in place that enables the organisation to promptly detect problems and undertake corrective actions. The internal audit function plays a critical role in assessing adherence to the company’s Business Ethics Policy.

  • Internal audits are conducted by Group Internal Audit (GIA). These audits include on-site visits, during which GIA auditors interview local management and employees to assess knowledge of Novo’s Business Ethics procedures and how effectively those procedures are being implemented.
  • In consultation with our Business Ethics Compliance Office, business ethics topics are built into GIA’s programme and are covered in each of GIA’s audits.
  • Since June 2007, Group Internal Audit has conducted more than 60 business ethics audits.

Reporting incidents

Novo Nordisk employees as well as external people can report any issue by contacting the Audit Committee directly through a dedicated website. All reports are investigated and reviewed by the Audit Committee.

Learn more about the Novo Nordisk whistleblower policy.