Human rights

Roche respects and proactively supports Human Rights.

1. Our Commitments

“Protect, Respect and Remedy” are the three pillars of Harvard Professor John Ruggie’s framework which was approved by the UN Human Rights Council and adopted in the UN Guiding Principles on Business and Human Rights (UNGPs) in 2011.

Roche fully supports and implements the UNGPs, and is equally committed to supporting the following:

  • The UN Sustainable Development Goals (SDGs)

  • The 10 UN Global Compact Principles

  • The Universal Declaration of Human Rights

  • The International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work

This commitment is embodied in our Roche Group Code of Conduct , the Roche Group Employment Policy , the Supplier Code of Conduct and in our Roche Position on Respecting Human Rights .

To fulfill its corporate social responsibility, Roche is committed to delivering continuous improvement and maintaining best practice at a policy and process level, as well as in its management approaches.

2. Our Impact on Society

For more than 125 years, both in our own operations and our value chain, Roche has in many ways fostered Human Rights globally. Within our sphere of influence, we proactively focus on improving global Human Rights by committing to doing no harm and making an impactful contribution.

By applying the principle of ‘knowing and showing’, Roche is committed to avoiding adverse impacts on Human Rights by focusing on the perspective of the rights holder. Roche Position on respecting Human Rights

3. Our Operations

Risk Assessment

We have implemented a risk management program designed to systematically identify, assess, mitigate and adequately manage the risk of Human Rights violations. The four identified top risks are:

Real World Data (RWD) and Real World Evidence (RWE) are seen as a potentially rich and underutilized source to generate insights as to how approved diagnostics systems and medicines affect outcomes for patients under real world conditions. We are committed to collecting and using data in a lawful, fair and legitimate way and will always respect the privacy of individuals in order to earn and deserve their trust.

Vulnerable group: Patient

We are committed to preventing and mitigating identified risks relating to a safe workplace. Roche observes all regulations in the area of safety and health at work, not only in respect of all its employees but also in respect of anyone else potentially affected by its activities. Employees must comply with the applicable safety, security, health and environmental legislation in force at Roche and workplace risk assessments with mitigation plans are performed in every affiliate.

Vulnerable groups: Employees of Roche and of our business partners.

Roche condemns all forms of child, forced or compulsory labour. Roche tolerates the employment of juveniles only where their employment is lawful and only under conditions which adequately safeguard their well-being. Roche does not tolerate:

  • any form of psychological, physical or sexual harassment, or any other violation of the dignity and respect of employees in the workplace.

  • any form of workplace discrimination based on gender, age, ethnicity, national origin, religion, disability, sexual orientation, HIV/AIDS status, citizenship, generic information or any other relevant characteristics protected under the applicable law.

Vulnerable groups: Employees of Roche and of our business partners.

Roche complies with all laws relating to employees respecting the right of employees to join a legally recognised employee association. We strive to set up and maintain an open dialogue with employee representatives. All of our operations respect the right of employees to freedom of association and collective bargaining. Employees can choose to be represented by unions, works councils or similar organisations, including the Roche Europe Forum, where employees from every Roche company in Europe are represented.

Vulnerable groups: Employees of Roche and of our business partners.

Roche also expects of its suppliers and other business partners to comply with all laws and regulations relating to the above mentioned risks.

Embedded in our operations

We embed Human Rights in our existing operations and daily business by multiple means:

(i) Benchmark

Within and beyond our industry.

(ii) Assessing actual and potential Human Rights risk

Within Roche and while doing business with our suppliers.

(iii) Increase awareness

Training on the basic principles of Human Rights is provided Roche-wide as part of a global mandatory eLearning. The completion rate in 2021 was 98%. Additional awareness initiatives are provided at the local, regional and global levels.

(iv) Foster due diligence

Including Human Rights aspects in due diligence activities associated with suppliers and business partners.

(v) Enhance legal framework

Having solid agreements in place with our suppliers and business partners

(vi) Collaborate in collective actions

Together with our peers we foster the protection of Human Rights through our work with organizations such as the Pharmaceutical Supply Chain Initiative ( PSCI ), of which we are a member.

(vii) Transparent communication

Via multiple internal and external channels.

All Roche departments and functions contribute to respecting and protecting Human Rights. For example, every site has a Human Resource contact supporting compliance with related principles such as discrimination and harassment, as outlined in the Roche Group Employment Policy .

4. Our Collaborations

We conduct risk-based due diligence on potential and existing suppliers and business partners. We hold our suppliers to high performance expectations that are aligned with our own values and principles. These are detailed in the Roche Supplier Code of Conduct that is referenced in every Roche contract. In order to enhance transparency within our sphere of influence, we also expect suppliers and business partners to actively assess and manage Human Rights risks in their own business partners.

Human Rights aspects are an integral part of the due diligence undertaken at the Group and Affiliate level, this includes by way of example:

1. Global Guidance & Checklists

on the Roche due diligence process, including instruction on how to develop and implement appropriate due diligence for local markets. Region specific toolkits are provided.

2. IT Tools

supporting a consistent end-to-end process which allows for recurring and systematic due diligence activities and risk assessments.

Human Rights Assessment and Implementation Framework

3. Robust third party risk management

embedding risk identification, monitoring and management processes throughout the supplier lifecycle.

Roche has a formal process and methodology for assessing our suppliers to identify those at higher risk for Human Rights violations due to:

  • Being associated with an industry that is likely to employ vulnerable populations

  • Being located in a region at higher risk for Human Rights violations, per respected Human Rights indices

  • Being associated with government, media or internal reports of alleged behavior or operations that indicate real or potential noncompliance with the Roche Supplier Code of Conduct

Roche selects its counterparties for acquisitions and divestments carefully from a general compliance and reputational perspective which includes but is not limited to Human Rights. Roche applies industry standard due diligence questionnaires to address health, safety & environment and employment related questions among a wide array of further matters which may relate to Human Rights. Depending on the counterparties, further risk based due diligence actions may be undertaken to ensure that issues such as human right violations, are detected and addressed.

5. Our Reporting

Employees as well as business partners are encouraged to speak up if they believe in good faith that a human right violation has occurred.

Our local and regional Compliance Officers serve as contacts for allegations, which are then reported via the Business Ethics Incident Reporting (BEIR) system to the Chief Compliance Officer (CCO) . Human Rights violations, especially of our suppliers, can also be identified by the Procurement department.

All allegations are taken seriously and are objectively investigated. If the allegation is substantiated, we take appropriate remedial measures.

In 2021, there were 4 substantiated incidents related to Human Rights, all related to Discrimination and Harassment. All of those triggered a termination.

In addition, we assess supplier compliance with our Human Rights standards through remote and onsite audits, our Supplier Sustainability Assurance Visit (SAV) program. In 2021:

  • We conducted 26 SSAVs at supplier sites (7 in Europe, 14 in APAC, 1 in North America and 4 in LATAM).

  • We had 52 Human Rights related observations for issues such as excessive overtime, incorrect overtime compensation, delayed payment of wages, and inadequate maintenance of employee time records.

  • Each of the 26 suppliers were required to establish and make progress on a formal corrective action plan(find an example here ).

All human beings are born free and equal in dignity and rights.
Universal Declaration of Human Rights
Article 1, 1948

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