Bribery and corruption

The Organization for Economic Cooperation and Development (OECD) has identified corruption as a prime threat to democratic process, sustainable economic development, good governance and fair business practices. In line with this, the international business environment - including the pharmaceutical industry - is facing increasing anti-corruption regulation and enforcement. Legislation generally prohibits the granting of benefits intended to maintain or obtain a business advantage, and carries criminal and other sanctions for violations.

In the US, amendments of the US Sentencing Guidelines in 2004 gave added impetus to compliance programs at major international companies around the world. Novartis leveraged the Amendments in further driving its compliance program to ensure that acts of bribery and corruption are actively discouraged and, where these do occur, that they are detected and sanctioned.

Our policy on bribery and corruption is clearly outlined in the Novartis Code of Conduct. Article 6 of our Code states that 'no employee shall make any payment, or kickback, or offer improper financial advantage to an official of a government, or a government-controlled entity, for the purpose of obtaining business or other services, as set out in the OECD Convention on Combating Bribery of Foreign Public Officials.' In addition, the Novartis Guideline on Business Ethics - Bribes, Gifts and Entertainment clearly outlines the scope, responsibilities, management process and reporting criteria for implementing this policy.

Our company position is clear: Novartis will not engage in bribery, either directly or indirectly. Bribery means to offer, promise or provide an undue benefit to a public official with the intention of obtaining or retaining an improper advantage by encouraging the official to act, or refrain from acting, in connection with an official duty. All activities of this nature are prohibited. Nor will Novartis engage in indirect bribery of public officials. The intentional use of intermediaries such as agents, advisors, consultants or other third parties for the purpose of committing acts of bribery is also prohibited.

To ensure that our values are translated into action, we have established a global Integrity & Compliance program to monitor conformity with our standards. This is backed up by a Business Practices Office, through which complaints and allegations of alleged misconduct can be reported confidentially. To facilitate compliance with anti-corruption legislation, new guidance on grants was drafted in 2006 in collaboration with the Basel Institute on Governance. This will be implemented in 2007 and prescribes clear standards, thorough reviews and proper recording of all types of grants.

 

Related links:

Transparency International business principles for countering bribery ›

OECD guidelines for multinational enterprises ›

IFPMA Code of Pharmaceutical Marketing Practices ›

WHO ethical infrastructure for good governance in the public pharmaceutical sector ›