Human rights
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All human beings are born free and equal in dignity and 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 and Roche Directive on Human Rights Due Diligence for Business Partners.
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
Roche fosters human rights globally, both in our own operations and across our value chain. We are evolving our holistic approach in the value chain towards a proactive approach in improving human rights by committing to doing no harm and making an impactful positive contribution to society.
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 a risk management approach designed to systematically identify, assess, mitigate and adequately manage the risk of human rights violations, including the assessment of whether there are reasonable grounds to suspect child labour. The Group human rights risk assessment covers our own operations and third-party operations. Its purpose is to identify and assess the potential negative human rights impacts of our activities and business relationships with a focus on own operations and the upstream supply chain.
Group human rights due diligence
Three-year cycle, review and update
Continuous cycle
1. Scoping, planning and value chain mapping
Identify and evaluate the relevant business relationships across our value chain
Gain a comprehensive understanding of the human rights risks that may arise throughout our core value chain
Identify areas for potential improvement
2. Data gathering
Gather relevant data by:
Review human rights standards
Examine Roche’s own policies and practices
Evaluate corporate performance
Conduct internal interviews
Engage with rights holders
3. Risk assessment
Identify human rights risks Roche may potentially cause or contribute to through its own activities or which are directly linked to its operations, products or services by its business relationships
Assess, consolidate and prioritise impact-based risks
Define risk mitigation strategies/plans
4. Integration and tracking
Monitor risk mitigation strategies/plans
Collect feedback from both internal and external affected stakeholders (leverage materiality assessment process when possible)
5. Communication
Establish form and frequency of communication accessible to all intended audiences
Educate internal and external stakeholders
The following focus areas based on impact were identified in our own operations:
| Focus areas | Background and commitments | Prevention and mitigation |
|---|---|---|
| Data Privacy | Data is a critical enabler of innovative treatments and diagnostic
solutions for patients and a key driver of business excellence. We aim to be a trusted and preferred partner to all individuals and groups who share data with us, including employees, patients and healthcare stakeholders. We are committed to collecting and using data in a lawful, fair, legitimate and ethical manner, consistently upholding individual privacy to earn and maintain trust. | We collect data in full compliance with relevant laws, such as the Swiss Federal
Act on Data Protection, the EU General Data Protection Regulation and the US
Health Insurance Portability and Accountability Act. Comparable adherence is
expected from our service providers and collaboration partners. We implement a comprehensive risk assessment and mitigation process to ensure data privacy. Other governance and protective measures are in place, led by the Chief Privacy Officer and the Global Privacy Office, in coordination with other functions. |
| Access to healtcare | As a healthcare company committed to advancing global health and
achieving the UN SDG 3, ensuring healthy lives and promoting well-being
for all at all ages, we leverage our expertise in pharmaceuticals and
diagnostics to make a significant impact on people and health systems. We strive to ensure that patients can benefit from our medicines and diagnostic solutions in a fast, broad and sustainable fashion, working on products that meet patients’ needs wherever they live. Our strategic ambition is to double the number of patients treated with innovative therapies in low- and lower-middle-income countries (LLMICs) by 2026, and to double global patient access to high-medical-value diagnostics by 2029. | We forge trusted global, regional and national partnerships to address
critical access gaps and ensure continuous investment in healthcare
innovation and services. We collaboratively develop and implement initiatives
that advance the prevention, treatment and management of diseases with
the highest societal burden. These include non-communicable diseases
such as cancer, diabetes and cardiovascular diseases, as well as infectious
diseases like HPV and HIV infection, tuberculosis and hepatitis C. We support countries in tailoring people-centric access initiatives to address their unique healthcare challenges, especially LLMICs, which, according to the World Bank, are home to 75% of the world’s population. Through our Global Access Program in the Diagnostics Division, we combine world-class expertise and innovation to expand access to reliable diagnostics, which is critical for controlling and advancing progress towards the World Health Organization’s infectious disease elimination goals. |
| Fair and safe work environment | We are committed to fair working conditions and respecting human
rights, which is reflected in the Roche Group Code of Conduct and the
Roche Group Employment Policy. We condemn all forms of child, forced or
compulsory labour. The employment of juveniles is only permitted when
legally compliant and under conditions that fully protect their well-being. We do 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, genetic information or any other relevant characteristics protected under applicable law. Prevention is the key driver for all SHE-related activities, decisions and measures at Roche. Our comprehensive approach to well-being thoughtfully integrates both organisational and individual perspectives. | We aim to prevent non-compliant behaviour by fostering a culture of
openness, providing designated contacts to address questions and
uncertainties about the Roche Group Code of Conduct. Roche Group companies are committed to properly implementing the Roche Group Employment Policy. Local policies are developed and communicated to meet the minimum standards. We observe all regulations in the SHE area in respect of all our employees and of anyone else potentially affected by our activities. Workplace risk assessments with mitigation plans are performed by every affiliate. A management system approach is in place to identify and control safety, security, health and environmental risks. Occupational health hazards are prevented or controlled through documented workplace health risk assessments, health surveillance, information and training for employees. |
Embedded in our operations
We embed Human Rights in our existing operations and daily business by multiple means:
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
Roche holds its suppliers to high performance expectations concerning human rights 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.
Our human rights commitment for business partners is based on the Pharmaceutical Supply Chain Initiative (PSCI) Principles, which we are committed to. The Principles are referenced in all Roche contracts and embedded in the provisions of the Roche Supplier Code of Conduct, which all our suppliers commit to.
We conduct risk-based due diligence on potential and existing suppliers and 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
The Roche Directive on Human Rights Due Diligence for Business Partners sets forth the framework and principles to ensure the protection of human rights across the Roche value chain. 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
IT Tools support a consistent end-to-end process which allows for recurring and systematic due diligence activities and risk assessments.
:quality(90)/ "Human Rights Assessment and Implementation Framework")
3. Robust third party risk management
As part of Group human rights risk assessment the following focus areas based on impact were identified in our supply chain.
| Focus areas | Background commitments |
|---|---|
| Working conditions | Suppliers shall adhere to applicable wage laws, including minimum wages, overtime hours and mandated benefits, and consider remuneration in accordance with the skills, performance and experience of their workers based on local competitive conditions. Overtime work shall be voluntary and suppliers are responsible for ensuring work schedules and hours comply with national and international standards. |
| Healthy working environment | Suppliers are expected to be committed to protecting human health, to understanding relevant workplace hazards and to effectively communicating such hazards and related protection to all potentially impacted workers. |
| Fair treatment and non- discrimination | Suppliers are expected to be committed to ensuring a workplace free of harsh and inhumane treatment, harassment and discrimination. This is especially important for migrant workers due to factors like national origin. |
Prevention and mitigation (for the above focus areas)
We require our suppliers to explicitly acknowledge and adhere to the principles of the Roche Supplier Code of Conduct. Suppliers shall ensure compliance with these principles along their own supply chains. Suppliers shall allow Roche to verify compliance with the Roche Supplier Code of Conduct through our PSCI-based Supplier Sustainability Assurance Visit (SSAV) programme. Suppliers at higher risk for human rights violations are included in a list of business partner auditable entities and scheduled for PSCI-based audits. Suppliers failing to meet Roche Supplier Code of Conduct expectations risk disqualification from working with Roche. Current suppliers not meeting expectations will have a mitigation plan; non-compliance may lead to termination.
* Pharmaceutical Supply Chain Initiative (PSCI:go.roche.com/pscinitiative)
We embed 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.
Inputs to our automated human rights risk assessment methodology that allows for traceability in the supply chain include an external perspective with risk assessment depending on four main externally available and recognised indexes: KidsRights Index, Global Slavery Index, OECD Index and Global Rights Index, using the following data:
Nature of product or service procurement category code identifying the supplier’s exact industry and the nature of its product or service – to assess associated human rights risk. We are looking for activities typically associated with vulnerable populations such as children, underage workers, migrants, local underprivileged communities and people with low levels of education.
Exact location of the business partner’s operations to assess if that area or region is associated with higher levels of human rights violations (i.e. limited regulation or enforcement).
History or new information on potential risk data input on external reports or concerns raised about a particular business partner, region or industry
Business partners identified as being at higher risk for human rights violations are included in a list of business partner auditable entities. These are scheduled for PSCI-based audits as part of our SSAV programme.
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.
4. Grievance mechanism
Employees as well as business partners are encouraged to speak up in good faith if they believe that a human rights violation has occurred. This also covers any reasonable concerns about the existence of a potential or actual adverse impact related to child labour.
The Roche Group speak-up channels are available for everyone internally and externally to report compliance concerns. Our local and regional Compliance Officers also serve as contacts for allegations, which are then reported to the Chief Compliance Officer via the Business Ethics Incident Management System ( BEIMS ). Human rights violations, especially by 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.
5. Our Reporting
In 2025, 10 substantiated incidents related to human rights violations triggered terminations of contracts. 9 incidents were linked to discrimination and harassment and 1 to data privacy, with 8 involving our employees and 2 our contractors; no incidents involved a business partner directly.
In addition, we assess supplier compliance with our Human Rights standards through our Supplier Sustainability Assurance Visit (SSAV) audit program.
In 2025:
We conducted 109 sustainability audits (SSAVs) at supplier sites (35 in EMEA, 53 in APAC, 2 in North America and 19 in LATAM).
We had 221 Human Rights related observations. The primary source of non-compliance within Human Rights & Labor Practices relates to working hours, with 34% of findings citing a lack of assurance regarding voluntary overtime. Additionally, systemic administrative gaps were observed, as several facilities lacked codified policies or statements of commitment regarding labor practices. Regarding child and young worker labor, 2025 audits found no active violations. Findings in this domain were exclusively administrative, stemming from inadequate policy documentation and insufficient follow-through on prior corrective actions.
Each of the suppliers where findings were identified, was required to establish and make progress on a formal corrective action plan.
Each of the 79 suppliers were required to establish and make progress on a formal corrective action plan.
Human rights-related findings per industry 2025
137
Logistics and transportation
28
Supply chain materials
16
Facilities and utilities
3
Workforce, training and employee services
30
Diagnostic instruments and software
2
Laboratory supplies
0
Engineering
2
Research and development
3
Supply chain services