Some of our activities relate to all or several principles in the UN Global Compact.
Ethics and behaviour
Our Code of Conduct is the corporate baseline for ‘doing the right thing’ and all our employees receive training on what this means in their job role. We continuously evaluate the need to update the principle-based Code, its related procedures and adapt the training. An update of the Code will be released in April 2016, which will contain additional principles for interactions with public officials, revised and more explicit guidance for interactions with healthcare professionals and patient organisations, and more specific principles for providing donations and grants.
Having the right principles in place is important and it is equally important to ensure that they are properly understood by the people they apply to. We place great emphasis on engaging managers and employees in discussions on how the principles and the more detailed requirements are transformed into action. Lundbeck’s Compliance Structure contains the three elements that ensure this: Documents, Training and Monitoring.
What is the right thing to do? This question is the centre of rotation for the Code of Conduct training that will be executed in the beginning of 2016. The participants are asked to resolve ethical issues and introduced to the four steps we consider part of a strong decision process: Think – Explore – Discuss – Decide. When applying these basic steps people are asked to challenge their immediate understanding of the situation, to consider the facts and develop their arguments, and to engage in dialogue with people who represent different perspectives before they reach a decision. Hereby we aim to support a culture where dialogue is the key to resolving ethical issues, which in fact is not different from making other decisions.
The final element in Lundbeck’s Compliance Structure is monitoring, which includes evaluating and auditing relevant business practices. These audits are planned while considering regulatory requirements and Lundbeck’s current risk map. The risk map is updated annually based on business activities, previous audit findings, trends in internal reporting and external sources capturing learnings from other companies and leading experts. In 2015, we conducted 148 internal audits that covered research, development, manufacturing, health, safety and environment (HSE), marketing, sales, IT and finance. In addition, we conducted 211 audits at key suppliers and partners.
Some of the audits are part of our supplier evaluation process, which forms a pivotal part of our anti-corruption measures and reflects our commitment to the ten UN Global Compact principles. These audits represent the most thorough control process we apply to select new or monitor performance of existing strategic suppliers. A greater proportion of our suppliers go through an integrated evaluation and due diligence process based on the UN Global Compact Principles. We ask all our suppliers and partners to sign a mutual commitment to compliance with human rights, employee rights, environmental protection and anti-corruption in our contracts.
Suppliers to manufacturing process have been subjected to these three levels of control since 2005. For the past three years, we have gradually extended these controls according to a prioritised plan, which will ensure that all purchases globally are covered. In 2015, the implementation was completed for all European affiliates, Canada and the US. In parallel, we updated the supplier evaluation process based on the gained experiences. It is our aim to finalise the global implementation of this process within 2016.
Promoting transparent interactions
Healthcare Professionals (HCPs) and Healthcare Organisations (HCOs) provide the pharmaceutical industry with valuable, independent and expert knowledge derived from their clinical experience. This expertise makes an important contribution to the industry’s efforts to improve the quality of patient care, with benefits for individuals and society at large. HCPs and HCOs should be fairly compensated for the expertise they provide.
Lundbeck believes that the transparency initiatives that are being enacted globally will ultimately enhance the general acceptance of these professional relationships. Lundbeck is currently reporting and disclosing these transfers of value where it is required.
We are committed to ensure that our compliance processes meet external requirements such as the European Federation of Pharmaceutical Industries and Associations’ Disclosure Code and local regulations. In 2015, we continued to enhance our process that asks relevant Lundbeck employees to follow specific requirements when planning interactions. During 2016, we will finalise the work to enable the public disclosure of interactions and the related transfers of value to HCPs and HCOs on an annual basis.