Compliance

Our company has a long-standing commitment to acting ethically and being a good corporate citizen. We comply with laws and regulations that govern our operations and activities, including how we research, develop, communicate and sell our medicines, vaccines, and other products.

We have a well-established compliance program that's consistent with recommendations and guidelines from government agencies, including the U.S. Department of Justice, the U.S. Department of Health and Human Services, and the UK Serious Fraud Office, as well as applicable industry associations’ codes of conduct (e.g., the Code on Interactions with Healthcare Professionals created by the Pharmaceutical Research and Manufacturers of America (PhRMA) and the International Federation of Pharmaceutical Manufacturers and Association Code of Practice).

Our compliance program is designed to prevent, detect and remediate potential violations of law or company policy.  We continuously assess and, where appropriate, make enhancements to ensure that the program is tailored to evolving business operations, considering developments in our industry and in the external enforcement landscape.

Our board of directors and senior management, including the company’s chief ethics and compliance officer, help oversee the program with support from various functions, including the Ethics & Compliance Office, Corporate Audit & Assurance Services, Global Investigations, and International Legal & Compliance. Divisional, regional and local market committees help operationalize and implement our company’s standards, policies, controls and processes. We use required enterprise training to reinforce key parts of the program, and our audit program tests how markets and business functions operationalize compliance requirements and processes.

Employees are required and encouraged to “speak up” and report potential violations of law or company policy, and there are multiple avenues for them to do so, including a confidential reporting telephone line and online tool operated by an independent third party. We're accountable for responding promptly to all reported concerns and thoroughly investigating to determine whether violations have occurred. As appropriate, we take disciplinary action and implement necessary remediation to consistently address instances of substantiated wrongdoing.  Substantiated violations are examined to assess whether the “root cause” reflects potential gaps in our compliance program and the most effective way to address and remediate to help prevent future violations.