Business Integrity & Responsible Marketing

We pride ourselves on doing business with integrity. We have a Guide to Integrity in Business Transactions to promote shared understanding of our standards of integrity throughout the Group, and to prevent violations of those standards.

The Guide covers:

• Bribery
• Granting of advantages
• Dealing with third parties
• Receipt of gifts and entertainment
• Conflicts of interest
• Remuneration of intermediaries

Behaviour in Competition: A Guide provides an introduction to antitrust and competition laws and is intended to raise employees’ awareness of how these laws apply to their business conduct and decision-making. It is essential that every Roche employee comply with competition laws, which serve to promote fair and honest competition.

Every effort is being made to inform and train Roche staff in this area: A specially developed interactive, computer-based learning programme is being deployed worldwide in every tier of management.

The Roche Group Insider Policy applies to Roche employees who have access to sensitive data or are authorised to undertake major financial transactions. A copy must be signed by every employee concerned. The Policy is intended to ensure that employees behave professionally and to reinforce Roche’s reputation as a trustworthy company and reliable partner.

The promotion and sale of pharmaceutical and diagnostics products is highly regulated. Roche has a strong commitment to comply with all applicable laws, regulations and industry codes, fully respects the position of trust of healthcare professionals which have to select the best diagnosis and treatment option for their patients.

Roche’s interactions with healthcare professionals are focused on the provision or exchange of scientific information with the ultimate objective to enable the healthcare professional to prescribe or use Roche’s product under those circumstances and conditions which deliver the greatest medical benefit to the patient.

Roche goes to great length to ensure adherence to high ethical standards. We have and continue to put in place all the necessary policies, guidelines and directives on good marketing practice. Training of all our staff interacting with healthcare professionals is a key priority for us.

Our Code of Conduct also guides our marketing practices. As with any other alleged violation of our Code of Conduct we diligently investigate any allegation that a specific marketing activity may not comply with our standards or applicable laws and regulations. Line management is responsible to ensure that the necessary corrective measures are made quickly and effectively.

In 2008, Roche introduced an online business ethics incident reporting system (BEIR) that enables the Group Compliance Officer and the Top Management to capture, track and monitor alleged violations, including non-compliance with good marketing practice, from initial reports by local compliance officers through to resolution. In our Annual Report 2008 we have reported about the number of reported ethical incidents as well as further aspects relating to responsible marketing.

The Group Compliance Officer together with Line Management makes sure that our organization is learning from the ethical incidents reported.