Corporate governance and compliance includes all of our efforts that promote our commitment to business integrity and to doing right by all of our stakeholders, including the people who use our medications, the healthcare community, shareholders, regulators, and employees.
At AstraZeneca US, the Corporate Responsibility Council spearheads our corporate responsibility efforts. Composed of a cross-functional management team, the Council reports through the Vice President of Policy, Legal and Scientific Affairs to the AstraZeneca Business Integrity and Assurance Team and the US leadership team. The Council recommends US CR Strategy, creates the US CR Action Plan, and leads implementation across the US organization. Together with our US Compliance Officer, the Council also coordinates with AstraZeneca globally to ensure that our US efforts are consistent with corporate expectations and that our US corporate responsibility strategy is reflected in our global priorities.
We recognize that compliance with clear standards and policies is essential to our company’s integrity and reputation. The Council chooses corporate responsibility efforts that promote our commitment to business integrity and to doing right by all of our stakeholders, including the people who use our medications, the healthcare community, shareholders, regulators, and employees.
Building awareness and commitment
All of our US employees, and external resource staff, are given training in our US Code of Conduct and other policies, including those directly related to CR, that are relevant to their roles and to sustaining an ethical culture within the company. CR also continues to be integrated into a range of business-related communications to ensure that understanding and committing to responsible behavior is part of everyone’s daily working life. This year, our comprehensive employee communication program for Compliance & Ethics was recognized as ‘Best Practice in Communications’ by the Pharmaceutical Compliance Forum.
Our ‘Exchange’ and ‘Voice’ initiatives enable US employee representatives to provide input into business and cultural program planning and to receive direct business briefings from leadership teams for onward communication within the AstraZeneca community.
Code of Conduct
AstraZeneca US enforces a Code of Conduct for all employees. This Code is the cornerstone of our US Compliance Program. Consistent with federal, state, and local laws, the Code focuses on regulatory matters and external affairs, financial and business conduct, and employment matters. A high-level summary of our Code of Conduct is available on our web site.
US Compliance Program
We have created a US Compliance Program to prevent, detect, and correct violations of company policies and procedures, as well as violations of applicable laws.
The AstraZeneca US Compliance Program is in accordance with the general principles of the Office of Inspector General (OIG) Compliance Program Guidance for Pharmaceutical Manufacturers that the US Department of Health and Human Services issued in May 2003. An overview of our US Compliance Program is available at
www.astrazeneca-us.com/content/aboutAZ/ourCompany/astrazeneca-corporate-compliance.asp.
Our US Compliance Officer leads this program and manages a department dedicated to this effort. Led by the Compliance Department, AstraZeneca has adopted policies and procedures designed to implement the general principles articulated in the Code of Conduct. We make clear to all employees the possible consequences of violating our standards and expectations, which may involve disciplinary action, up to and including dismissal.
To ensure that all our employees understand our commitment to compliance, we deliver mandatory compliance training for all new hires and job-specific compliance training for current staff. Each year, every AstraZeneca US employee must also complete Code of Conduct training designed to keep him/her current on key policies. In 2006, AstraZeneca employees and key external resource personnel, in total, completed more than 25,000 compliance-related training sessions.
Complementing our compliance training is our rigorous auditing program, which helps ensure independent and objective review and assessment of our compliance efforts. In addition to formal audits, we monitor specific risk areas through periodic compliance assessments.
To support AstraZeneca’s core values and commitment to compliance and ethics, we provide tools for seeking guidance or reporting activities that may involve unlawful conduct or violations of the AstraZeneca Code of Conduct or policies. The toll-free Code of Conduct Helpline (866 99ETHICS) and the AZEthics.com web site are both available to all AstraZeneca employees and contractors 24 hours daily/7 days a week. AZEthics.com is also available to non-employees at all times at www.AZEthics.com. We handle each reported violation on a case-by-case basis, and take consistent disciplinary action to address inappropriate conduct.
Because compliance is a dynamic concept, AstraZeneca performs risk assessments on the overall effectiveness of our Compliance Program at least annually. As part of this assessment, AstraZeneca may modify aspects of the program to enhance its effectiveness.
Expectations of our supply chain
We apply our principles to suppliers as well. In 2006, we formally informed all AstraZeneca suppliers of our corporate responsibility principles and encouraged their adherence. We also provide new suppliers with specific details about our policies and expectations, the language of which has been added to all AstraZeneca US contracts. We work closely with our key suppliers to review their corporate responsibility compliance, identify issues of concern, encourage and facilitate continuous improvement, and, where necessary, seek alternative suppliers whose performance and commitment are consistent with our established principles.
