Integrity and Responsible Marketing

As one of the world’s largest healthcare companies, Roche takes seriously its obligation to meet the highest standards of business ethics and integrity. Meeting those standards is the responsibility of all our employees.

To promote and support a shared understanding of our standards of integrity, and to prevent violations of those standards, we publish several detailed directives, guidelines and policies:

• Behaviour in Business seeks to prevent the infringement of business integrity by addressing topics such as bribery, granting of advantages, dealing with third parties, receipt of gifts and conflicts of interest.
• Behaviour in Competition helps raise awareness of how antitrust and competition laws apply to business conduct and decision-making. We make every effort to inform and train all employees in this area, including providing an interactive learning programme.
• Roche Group Insider Policy applies to and must be signed by employees who have access to sensitive data or who are authorised to undertake major financial transactions. The policy is intended to ensure professional behaviour and to reinforce Roche’s reputation as a trustworthy company and reliable partner.

The pharmaceutical industry is governed by strict regulations and guidelines for the sale and marketing of products. Our Code of Conduct addresses responsible marketing practices, setting out standards for adhering to regulatory compliance and for interacting and engaging with healthcare professionals. Roche’s interactions with healthcare professionals are aimed at exchanging scientific information that can help to optimise the use of Roche’s products and services. All these interactions are based on standards of integrity and fair remuneration for services.  We are committed to benchmarking our achievements against best practice; this includes transparent reporting.

The goal is to enable healthcare professionals to make decisions independently, based on all relevant data available, for delivering the greatest medical benefit to patients. To help us maintain good marketing practices, we expect all employees to:

• comply with applicable laws, regulations, industry codes and Roche’s internal and standards
• speak up and take immediate corrective measures in the event of compliance concerns
• defend Roche’s interests against unfair competitive practices

We specifically train staff who interact with healthcare professionals and maintain rigorous standards of risk management and compliance.

The Chief  Compliance Officer  captures, tracks and monitors alleged violations, including non-compliance with good marketing practice, from initial reports by local compliance officers through to resolution through an online business ethics incident reporting system (BEIR).As with any alleged violation, 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.

The Chief Compliance Officer coordinates the network of local Compliance Officers and ensures that best practice examples and lessons learnt from reported ethical incidents are regularly exchanged and shared within Roche’s compliance network.