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
Report concern using one of the SpeakUp platforms*
Review
Concern reviewed to decide next steps
Investigate
Local or global function investigates
Decision
Business decides on appropriate action
Update
Employee will be updated on the case
Action
If required, actions will be put into practice
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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2020 |
2019 |
2018 |
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Novartis associates trained and certified on the Code of Ethics (%)1 |
98 |
98 |
98 |
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Misconduct cases (central matters) reported to the SpeakUp Office2, 3, 4 |
142 |
209 |
441 |
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Total SpeakUp Office allegations (central matters)2, 4, 5 |
243 |
427 |
768 |
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SpeakUp Office allegations (central matters) per category (%)2, 7 |
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Fraud/asset misappropriation |
7.8 |
6.8 |
21.6 |
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Expense fraud |
2.9 |
5.4 |
23.48 |
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Books and records, accounting irregularities |
0.8 |
1.2 |
0.4 |
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Improper professional practices |
11.9 |
16.9 |
22.3 |
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Bribery, kickbacks |
0.8 |
1.6 |
2.1 |
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Discrimination and sexual harassment |
12.8 |
8.2 |
4.0 |
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Retaliation |
3.0 |
6.3 |
2.1 |
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Other employee relations issues |
19.0 |
18.0 |
7.9 |
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Conflict of interest |
10.7 |
10.8 |
5.2 |
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IT security breach |
3.7 |
4.0 |
1.9 |
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Quality assurance/data integrity |
8.6 |
6.3 |
3.1 |
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Data privacy |
1.6 |
2.6 |
0.5 |
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Antitrust, fair competition |
0.8 |
0.2 |
0.3 |
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Company confidential/trade secret information |
3.7 |
0 |
0 |
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Other |
11.9 |
11.7 |
5.1 |
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SpeakUp Office allegations (central matters) substantiated2, 4, 6 |
114 |
254 |
558 |
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Dismissals and resignations related to misconduct (central matters)2, 4, 6, 9, 10 |
102 |
186 |
350 |
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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.