Lundbeck promotes business ethics by enforcing our corporate principles and supporting a culture that acknowledges open discussion of ethical dilemmas in our own operations and among key stakeholders.
Lundbeck is actively engaged in working against corruption in any form and we apply our business ethics standards across our value chain. We have a zero tolerance policy for bribery and require that our partners also adhere to our ethical standards.
Our Code of Conduct represents the policy level and contains the key principles that address business ethics in our compliance structure. This is supported by both corporate and local procedures for our interactions with suppliers, healthcare professionals and key stakeholders like public officials. Lundbeck’s procedures for authorisation and signing also address our anti-corruption commitment and help ensure that Lundbeck enters into agreements and makes purchases in a transparent and responsible manner.
An open dialogue on ethical dilemmas is at the foundation of our approach to prevent corruption. This dialogue is supported through regular training for all employees that places our Code of Conduct and related procedures in a business context. We systematically monitor adherence to our Code of Conduct through our Compliance Hotline1, business ethics audits and quarterly compliance reporting from our business units and global affiliates.
Current risk map directs our preventive measures
Every year, our global team of auditors updates Lundbeck’s compliance risk map based on business activities, audit findings, trends in internal reporting and external sources that capture learnings from other companies and leading experts. The current risk map is used to keep our corporate procedures up to date, prioritise new preventive measures and plan monitoring activities.
During 2015, we updated the Code of Conduct and the changes, in different ways, relate to strengthening our approach to business ethics. To mention a few examples, we added new principles for interactions with public officials, provided more direct guidance regarding what constitutes a conflict of interest and we made the requirements for organising or sponsoring interactions with healthcare professionals more explicit. Adherence to Lundbeck’s Code of Conduct and related procedures is monitored via systematic audits that have specific focus on business ethics. Our dedicated business ethics auditors visited nine Lundbeck business units in 2015.
The principal changes to the Code of Conduct have been included in the update of the more detailed global procedures, for instance our procedure for selecting and evaluating suppliers. This rigorous evaluation process involves a review of prospective supplier’s commercial capabilities, their quality standards, the adequacy of their business ethics controls and their overall performance. During 2015, our skilled employees working with engaging suppliers asked our compliance experts at Lundbeck’s headquarters to conduct a thorough assessment of 111 suppliers. In seven of these cases the final decision was not to proceed with the supplier. In addition to the mentioned controls, we conducted 211 audits at key suppliers and partners during 2015.
Third parties are asked to follow our Code of Conduct
Suppliers that perform activities within Lundbeck’s core business areas either on behalf of or in the material interest of Lundbeck are called third parties. Since establishing our Code of Conduct, we have asked third parties to adhere to the principles in the Code as part of the agreement with Lundbeck. In a few cases this has also included training and auditing of their adherence to the obligation.
In 2015, our business ethics auditors have trained other Lundbeck auditors to integrate business ethics aspects into their audit activities of supplier and partners. They have also been working on making business ethics training of third parties more systematic. In 2016, we aim to finalise this work and introduce business ethics training for selected third parties.
1 The Compliance Hotline is available for reporting legal or other serious concerns, which cannot otherwise be properly addressed. Reports are handled strictly in accordance with our global investigation procedures, including relevant data protection requirements and Lundbeck’s non-retaliation policy, which does not accept any retaliation or discrimination against anyone who communicates a concern in good faith.
The UN global compact anti-corruption principle
Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery