Our approach to sustainability

As sustainability is built into our business strategy, a strong commitment from all business areas and senior management is reflected in our sustainability governance structure:

Oversight of sustainability at Roche

• The Board of Directors(BoD) is ultimately responsible for the overall management of the company and the supervision thereof including the related topics pertaining to sustainability. In accordance with the Bylaws the BoD has established the Corporate Governance and Sustainability Committee (CGSC)  which supports and manages the oversight and governance of sustainability at Roche. Among other things the BoD remains for example responsible for signing off the sustainability report.

• The Corporate Governance and Sustainability Committee(CGSC) assists in an advisory and preparatory role the BoD in fulfilling its ultimate responsibility and accountability for corporate governance, sustainability and non-financial reporting at Roche. Within that framework it monitors and approves  the governance and management of sustainability matters at Roche.

Ownership of sustainability at Roche

• The Corporate Executive Committeeis responsible for sustainability at Roche, including the implementation of the sustainability strategy, apart from the matters which require direct involvement of the BoD. The Head of Corporate Strategy and Sustainability, supported by the Chief Sustainability Officer, is responsible for establishing, managing, and coordinating the implementation of the sustainability strategy.

Steering of sustainability at Roche

• The Corporate Sustainability Committee (CSC) steers sustainability at Roche through strategic advice and guidance, progress review towards achieving the sustainability ambition and goals as well as facilitates the removal of potential barriers. It also fosters a culture in which sustainability is systematically considered in decision making.

• Cross divisional committees and / or teams steer specific areas of sustainability. The CSC can recommend the setup of a cross functional committee and or team either on a permanent or temporary basis on specific topics, e.g. carbon reduction or emerging legislations.

  Implementation of sustainability at Roche

• Pharma division, Diagnostics division and Group Functions

  The accountability of implementation of sustainability at Roche is anchored in the Pharma and Diagnostics division together with the Group Functions. It includes setting division specific sustainability goals, definition and implementation of action steps to reach the sustainability ambitions and goals.

• (Existing) communities, networks and grassroot initiatives

  (Existing) communities, networks and grassroot initiatives contribute to the implementation of sustainability at Roche. The communities act independently on their purpose. They are encouraged to align their priorities with the priorities of the sustainability strategy.

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

Our standards of business integrity are set forth in our Code of Conduct, which include the Corporate Principles.

To further promote and support a shared understanding, Roche has implemented a number of policies, directives, position statements and guidelinesthat apply across the Group. Employees at all Roche sites have access to all external and internal documents either electronically (e.g. on the Roche intranet) or as hard copies.

Detailed guidance has been issued for example:

• The Behaviour in Business Directive on Integrityseeks to prevent the infringement of business integrity by addressing topics such as bribery, improper advantages, facilitation payments, gifts, entertainment, dealing with business parties and conflicts of interest.

• The Behaviour in Competition– A Guide to Competition Law helps raise awareness of how antitrust and competition laws apply to business conduct and decision-making.

• The Roche Group Insider Directive - intends to ensure professional behaviour and reinforce Roche’s reputation as a trustworthy company and reliable partner. An insider declaration must be signed by employees who have access to sensitive data or who are authorised to undertake major financial transactions.

We make every effort to inform and train all employees, and business critical contractors on the basic business standards, including providing interactive learning solutions.

The pharmaceutical industry is governed by strict regulations and guidelines for the sale and marketing of products. Our Code of Conductaddresses 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 intended 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.

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

• comply with applicable laws, regulations, industry codes and Roche standards

• defend Roche’s products and interests against unfair competitive practices

• seek help and advice in case of doubt

• speak upin the event of compliance concerns

We specially train staff who interact with healthcare professionals and healthcare organisations and maintain rigorous standards of risk management.In addition, Roche uses a Marketing and Sales Compliance questionnaire to help local line managers assess compliance and awareness of responsible marketing practices. Equally, all general managers must annually sign an “assurance declaration on compliance”, acknowledging compliance with these practices.

In addition, Roche uses a Marketing and Sales Compliance questionnaire to help local line managers assess compliance and awareness of responsible marketing practices. Equally, all general managers must annually sign an “assurance declaration on compliance”, acknowledging compliance with these practices.