Holding ourselves to high ethical standards

Acting in an ethical manner is essential to building trust with society. Our stakeholders not only expect us to do what is legally required, but also to follow high standards of ethical behavior wherever we operate.

Supporting ethical decision-making

We are making progress in embedding our Code of Ethics across the organization and supporting employees to do what’s right when faced with ethical dilemmas.

In 2021, around 98% of employees completed e-training on the Code of Ethics. In addition, around 84 000 employees visited an internal Code of Ethics information platform and around 65 000 accessed an online tool called Decision Explorer that provides guidance to help resolve ethical dilemmas. We also launched a toolkit to support leaders in discussing ethical dilemmas with their teams.

We improved the way we manage conflicts of interest with the release of a revised framework, including a new guideline, disclosure process and supporting tool. Around 97% of employees completed a declaration on potential conflicts of interest.

Further, we took steps to integrate an ethics dialogue into the process for recruiting potential new employees. In 2021, we launched a guide for interviewers to assess the ethical profile of potential hires and their fit with the Novartis Values and Behaviors and our Code of Ethics. By signaling that ethics and integrity matter to Novartis during the first interaction with a candidate, we improve our chances of hiring high-integrity individuals who are a good fit for our ethical culture.

In our Code of Ethics, we commit to use artificial intelligence in a transparent and responsible way. In 2021, we were one of the first companies to issue a position statement on the topic. For more information, please see the section “Go big on data and digital.”

Advances in digital technology have led to new, more personalized ways of engaging with our customers across multiple channels. To ensure we navigate these changes in the external environment ethically, we are adjusting our Professional Practices Policy and processes to create consistency in how we manage new relevant types of compliance risks. We have rolled out a global system architecture to ensure our processes are implemented consistently across markets.

Measuring our ethical climate

We launched our first annual global ethics survey in 2021 to measure our progress in embedding our Code of Ethics across the organization. Translated into 15 languages, the survey was sent out to 150 000 Novartis employees and external contractors.

The results from more than 50 000 responses to the survey provide us with robust data across different parts of the company to evaluate the effectiveness of our policies, programs and controls. Importantly, they also help us identify areas where we may need to reinforce our ethical culture and climate. We are working to turn these insights into processes and tools to further encourage ethical behavior, and we plan to repeat the survey in 2022 to gain further insights.

Anti-bribery policies and practices

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.

Novartis participated in a collective action initiated by Norges Bank Investment Management (NBIM) to jointly develop a reporting standard on anti-bribery. In early 2022, we published our first anti-bribery report based on the guidance issued by NBIM and aligned with principles such as the United Nations (UN) Global Compact and the OECD Guidelines for Multinational Enterprises.