Encouraging associates to speak up

The SpeakUp Office continues to provide a safe place for associates to raise concerns about potential misconduct while being protected against retaliation. Complaints can be made directly to the SpeakUp Office through an external web-based platform, which offers the possibility to report anonymously, or through our mobile app. Complaints can also be raised via a generic email address to the SpeakUp Office; through local channels such as the ERC, P&O and Legal functions; or to senior management. Our process helps ensure that complaints are swiftly received, risk-assessed, prioritized, investigated, and resolved at the appropriate level. We are committed to analyzing and understanding the root causes of misconduct to help prevent similar issues from occurring in the future.

In total, 1 941 complaints of alleged misconduct, with a total of 2 186 allegations, were made. 22% were self-identified (monitoring), and 78% came from SpeakUp. 35% were made anonymously. There was a 17% decrease in overall complaints in comparison to last year (similar to peers) due to COVID-19 and the stricter risk assessment.

Our SpeakUp process

Report (Icon)

Report

Report concern using one of the SpeakUp platforms*

Review (Icon)

Review

Concern reviewed to decide next steps

Investigate (Icon)

Investigate

Local or global function investigates

Decision (Icon)

Decision

Business decides on appropriate action

Update (Icon)

Update

Employee will be updated on the case

Action (Icon)

Action

If required, actions will be put into practice

Close (Icon)

Close

SpeakUp case closed

* Externally hosted web-based platform (web form or hotline) or via local channels, such as the ERC, People & Organization, and Legal functions or senior management

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Ethical business practices performance indicators

 

2020

2019

2018

Novartis associates trained and certified on the Code of Ethics (%)1

98

98

98

Misconduct cases (central matters) reported to the SpeakUp Office2, 3, 4

142

209

441

Total SpeakUp Office allegations (central matters)2, 4, 5

243

427

768

SpeakUp Office allegations (central matters) per category (%)2, 7

 

 

 

Fraud/asset misappropriation

7.8

6.8

21.6

Expense fraud

2.9

5.4

23.48

Books and records, accounting irregularities

0.8

1.2

0.4

Improper professional practices

11.9

16.9

22.3

Bribery, kickbacks

0.8

1.6

2.1

Discrimination and sexual harassment

12.8

8.2

4.0

Retaliation

3.0

6.3

2.1

Other employee relations issues

19.0

18.0

7.9

Conflict of interest

10.7

10.8

5.2

IT security breach

3.7

4.0

1.9

Quality assurance/data integrity

8.6

6.3

3.1

Data privacy

1.6

2.6

0.5

Antitrust, fair competition

0.8

0.2

0.3

Company confidential/trade secret information

3.7

0

0

Other

11.9

11.7

5.1

SpeakUp Office allegations (central matters) substantiated2, 4, 6

114

254

558

Dismissals and resignations related to misconduct (central matters)2, 4, 6, 9, 10

102

186

350

1

Active Novartis associates with email addresses, trained via e-learning or via One Deck for Novartis Technical Operations. Training rolled out from September 2020 to February 2021, with a preliminary completion rate as of December 31, 2020.

2

A central matter applies to a senior leader or manager, potentially disruptive reputational impact, sexual harassment, discrimination, retaliation and significant financial impact.

3

The number of misconduct cases reported may change year-on-year as matters may be reassessed in the course of the case lifecycle.

4

The decrease in the number of misconduct cases reported is due to a new risk assessment as of 2019.

5

The number of allegations is higher than the actual number of cases as a case can have more than one allegation.

6

May include allegations from previous years

7

Percentages are based on total SpeakUp Office allegations number. Results for 2019 and 2018 have been revised to reflect the change in methodology from using the number of misconduct cases to the number of allegations.

8

Until the end of 2018, these expense fraud allegations are assessed to be of higher risk in China. The risk assessment of these issues changed as of 2019.

9

Data based on when investigation report was received. Results for 2019 and 2018 have been revised to reflect this change in methodology.

10

Data based on year when case is closed. Results for 2019 and 2018 have been revised to reflect this change in methodology.

Complaints fell under 15 categories (see the prior table). In 2020, we factored human rights-related violations into our existing misconduct categories; within these categories, nine cases contained allegations of human rights violations.

Overall, the investigated central matter allegations (higher-risk cases) resulted in 102 dismissals or resignations, and in 68 written warnings. Other remedial actions such as training, coaching and implementing new controls were also widely used when deemed appropriate.

We continued to strengthen the SpeakUp Office with general awareness sessions about the program, and together with the Global Security team responsible for investigating most central matter allegations, we offered training on specific investigations to upskill local case managers in ERC and P&O teams. A total of 755 associates were engaged, and more than 150 completed virtual training sessions.