Anti-bribery and anti-corruption

Our Anti-Bribery Policy states expectations for all employees, and we also clearly state our standards in our Code of Ethics. Specific principles are set out in our Professional Practices Policy, while third-party risk is governed by our Anti-Bribery Third-Party Guideline. Our SpeakUp Office investigates allegations of misconduct. In early 2022, we published our first anti-bribery report based on guidance issued by Norges Bank Investment Management (NBIM) and aligned with principles such as the United Nations (UN) Global Compact and the OECD Guidelines for Multinational Enterprises.

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Human Rights

Novartis is committed to conducting our business in a manner that respects the rights and dignity of all people that may be affected by our business activities. We adopted our first Human Rights statement in 2003, and we continue to make progress in expanding our efforts to respect human rights within our operations and throughout our supply chain. 

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Political involvement

At Novartis, we strive to engage in constructive dialogue with policymakers and other external stakeholders with the aim of improving access-to-medicines and patient outcomes. Our intent is to represent the perspective of Novartis in the policymaking process by providing data and insights which enable informed decision-making. We undertake political activities in a responsible and ethical manner with a view to creating a sustainable business environment. Our political activities include responsible lobbying, monitoring of the political environment at a global, regional, and local level, engagement with trade associations and financial contributions to support the political dialogue. 

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Responsible promotion and marketing of products

Novartis has adopted a single set of ethical principles that should be applied in daily decision making by all Novartis employees in any customer interaction and professional practice-related activity. 

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Other information

  • Audit and control procedures on responsible marketing
    • Novartis has established a comprehensive compliance framework (guided by our Professional Practices Policy), which addresses how to address promotional and non-promotional materials; events; professional meetings; medical utility and cultural acknowledgements; external funding; HCP and HCO engagements; interactions with patients and patient organizations; and market research.
    • To ensure processes are implemented, Novartis has established a comprehensive monitoring and audit framework, which comprises three types of activities:
      • Local commercial country organizations make a compliance self-risk assessment against. the established P3 compliance framework using the Risk Assessment & Monitoring tool, which highlights risk areas requiring further attention.
      • A central independent worldwide compliance monitoring team has been established in January 2020. This team partners with local businesses to assess how effectively the Novartis compliance framework guides our associates. Each review is concluded with a report and agreed remediation actions. Remediation actions are defined to address identified gaps, and a dedicated Remediation Team has been established in February 2020 to strengthen follow-up.
      • Novartis has also established a comprehensive third-party risk management program, which among other risk areas, addresses anti-bribery risks. Once a third party is on-boarded, it can be subject to anti-bribery audits conducted by Novartis or an external audit company.
    • Further, Internal Audit performs audits spread over 6 blocks per year, including in-market audits and functional audits. 
    • Final audit reports are shared with members of the Executive Committee of Novartis (ECN) and other Novartis stakeholders. All high and medium observations from audits are reported, and they are rated based on their impact on the local, cross-divisional or group level.
    • The Audit and Compliance Committee (ACC) from the Board of Directors receives a summary of these reports every quarter. “Needs Major Improvement” (i.e. serious breaches or major deviations from regulations or policies putting the organization at risk) and “Leading” (i.e. effective and efficient controls, showing a continuous improvement cycle) reports are submitted to the ECN and the ACC.
  • Alignment with external guidelines on responsible marketing
    • The Novartis P3 policy reflects several industry codes including but not limited to the Code of Practice of the International Federation of Pharmaceutical Manufacturers & Associations and the Ethical Criteria for Medicinal Drug Promotion established by the World Health Organization.

Transparency and disclosures

Transparent reporting and disclosure play a key role in building trust with society. Novartis applies and supports laws and regulations that promote transparency around relationships between healthcare companies and healthcare professionals, healthcare organizations and patient organizations, and related transfers of value. For patient organizations, Novartis goes beyond the reporting requirements set by the EFPIA (European Federation of Pharmaceutical Industries and Associations) Code of Practice. We publish a global report covering transfers of value made to patient organizations in all countries where we operate.  

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