Ethics, Risk and Compliance

Holding ourselves to the highest ethical standards

As a Novartis company, we aspire, as part of our vision, to be a trusted leader in changing the practice of medicine. To realize this vision, we need to earn and maintain the trust of patients, associates, healthcare partners, shareholders and the society we serve.

We recognize society’s expectations of our industry and of AAA, and that we must go beyond just doing what is legal in order to meet legitimate expectations of society.
Our aim is to prevent issues from occurring, drive personal accountability for behaviors, and generate learnings that can be applied across the organization. In addition, we maintain a strong commitment to upholding human rights and managing risk in our supply chain. We began this journey some years ago, and we continue to make progress.

At Novartis, in 2014, the position of Chief Ethics and Compliance Officer, reporting to the CEO was created, elevating the Compliance function to the highest levels in the company. On April 1, 2018, the risk management and compliance functions were combined into a single organization called Ethics, Risk and Compliance (ERC), and announced the new role of Chief Ethics, Risk and Compliance Officer, which was further elevated to become a member of the Executive Committee of Novartis.

As we reimagine medicine, we need to help ensure that our leaders and employees act appropriately when faced with ethical dilemmas and effectively meet society’s increasingly high expectations. To further reinforce principles-based thinking and ethical decision-making in our organization and interactions with external stakeholders, we developed our Code of Ethics, replacing our Code of Conduct as of September 1 2020. Building on our Professional Practices Policy, and rooted in behavioral science, the code was co-created by our people, for our people. More than 2 500 Novartis associates shared ideas and insights during an early-stage crowdsourcing, and 1 500 participated in a global engagement to encourage open conversations around ethical dilemmas. The code was launched during EthicsWeek 2020 – a week dedicated to global events and activities around the world celebrating ethics.

As a Novartis company, at AAA we hold ourselves to the highest ethical standards and do not tolerate unethical behavior. We are taking all necessary steps to enable associates to do what’s right and ensure compliance with our Code of Ethics and all applicable laws, regulations, industry codes, policies and procedures. At the same time, we cannot exclude the possibility of misconduct by individuals. We therefore have extensive measures in place in an effort to ensure that reports of suspected misconduct are investigated thoroughly. Where misconduct is found, we work to take swift and appropriate action.

With a goal of ensuring accountability of local country organizations, our management includes integrity and compliance questions as part of standard business reviews. We work to identify and mitigate risk exposure proactively so it can be reviewed and discussed at a management level.

Our goal is to maintain consistent standards of business practices across AAA, ultimately enabling us to provide the best possible care for patients globally.

The Global Ethics, Risk & Compliance function designs and implements compliance programs associated with the Novartis Code of Ethics (PDF 4.2 MB), Anti-Bribery Policy (PDF 0.2 MB) and Professional Practices Policy (P3) (PDF 1.0 MB). The Ethics, Risk & Compliance function drives the implementation of these programs, with the goal of ensuring ethical business practices by all associates.

Code of Ethics

Our commitment to doing what’s right

As a Novartis company, AAA is committed to ensuring our associates are empowered to do what’s right. On September 1 2020, we introduced a new Code of Ethics for Novartis, including AAA. Created by our associates, for our associates, our new Code is a collection of our commitments to ethical standards across our business.

Our Code of Ethics was co-created with the inputs of thousands of associates. It is anchored in behavioral science, and underpinned by four clear ethical principles:

  • Be Open-Minded
  • Be Honest
  • Be Bold
  • Be Accountable

The Code of Ethics replaces our former Code of Conduct and is a fundamental part of the terms of employment for all associates of Novartis. All associates receive the Code when they join Novartis and are held accountable to its contents. It is available in 22 languages and has been adopted by local boards.

The Code contains our principles and expectations for ethical business conduct that help guide our associates in making the right decisions when they encounter difficult situations or ethical challenges during the course of their work.

Our Ethical Principles

The Code of Ethics focuses on our commitment to meet the expectations of our five key stakeholder groups: our patients, associates, shareholders, healthcare partners and society. While our purpose – to reimagine medicine to improve and extend lives – drives our values and defines our culture of inspired, curious and unbossed, our ethical principles guide us in our everyday decision-making and ensure we act with integrity.

Ethical Decision Making Framework

Because ethics isn’t black and white, we’ve created an online, interactive ethical decision making framework to guide our associates towards better decision making. The framework guides users through 15 questions, prompting deep reflection as part of the decision-making process, surfacing up to 6 possible biases and suggesting materials and resources for further learning. The framework does not replace conversation and consultation, and does not give a definitive answer about what one should do, but it helps broaden perspectives and encourages better understanding and application of our ethical principles.

AAA expects leaders to lead by example. This means that leaders must accommodate ethical considerations in business planning and decision-making, empowering associates to make responsible decisions, and creating a safe environment to speak up when ethical challenges arise.

Training and guiding associates

Awareness and training programs are offered regularly in a range of formats, including awareness-building programs, e-training, face-to-face programs, games and workshops. We provide extensive communication toolkits to support awareness programs at the local level.

All Novartis associates are required to complete ethics, risk and compliance training. Our global e-training curriculum provides relevant information to enable associates to make the right choices in the course of their work and to perform with integrity. It addresses identified and relevant company risks and helps to communicate new and upgraded policies and guidelines across the organization.

Training on ethical business practices is included in our Corporate Leadership Learning programs, and we provide extensive training for our Ethics, Risk and Compliance Officers across the company.

Handling complaints

We require associates to report actual or suspected violations of our Code of Ethics, but realize that fear of reprisals can make people hesitant to speak up. This is why we enforce clear policies to prevent retaliation against any associate reporting an issue.
The SpeakUp Office (formerly named Business Practices Office) offers employees and people outside of AAA a channel through which to report misconduct. Complaints can be made by email, phone, online or in-person. The web-based and telephone channels are operated via a third-party vendor. The SpeakUp Office manages investigations into all complaints, and escalates any substantiated cases of misconduct to management for appropriate action.

Code, Policies and Guidelines

Our Policies and Guidelines are a key element of our corporate responsibility. They define how we want to conduct business, what we expect of ourselves and our business partners throughout the world.

Our Policies contain governing principles and procedures to effectively manage a topic and are broadly applicable. They are updated every three years on average. Our Guidelines are subsidiary to Policies, where they exist, and to Code of Ethics topics otherwise. Guidelines clarify and amplify important principles and are based on best practices or mandatory rules. They are generally updated on an annual basis.

Novartis Code of Ethics (PDF 4.2 MB)

Novartis Anti-Bribery Policy (PDF 0.2 MB)

Novartis Professional Practices Policy (PDF 1.0 MB)

Novartis Data Privacy Principles (PDF 0.2 MB)

Novartis No Purchase Order (PO) No Pay Policy (PDF 0.1 MB)

Code of Ethics

Our Code of Ethics, created by associates for associates, sets out 22 commitments we make to doing what’s right. Underpinned by four ethical principles – Be Open-minded, Be Accountable, Be Bold, Be Honest – the Code of Ethics replaced our Code of Conduct on September 1 2020.

Anti-Bribery and Anti-Corruption

As a Novartis company, AAA does not tolerate bribery or corruption in our operations and our Anti-Bribery Policy explicitly states expectations for all associates.

Professional Practices

As a Novartis company, AAA applies a single set of ethical principles to daily decision-making regarding any customer interaction and professional practice-related activity.

Data Privacy

As a Novartis company, AAA is committed to protecting the privacy and personal data of all patients, employees, consumers and investors.

Risk Management

As a Novartis company, AAA strives to reduce risk and ensure continuity at both strategic and operational levels with risk portfolios and continuity management audits.

Responsible Supply Chain Management

We work to ensure that our commitment to corporate responsibility is reflected in how we select and work with our suppliers.

Human Rights

As a Novartis company, AAA respects and supports the protection of human rights in its operations and supply chain as enshrined in the Universal Declaration of Human Rights.