As a global company, we work across many diverse cultures where concepts of appropriate business conduct can vary widely. We believe ethical business conduct is about values and integrity as well as compliance and risk mitigation. Taking a proactive approach in ethical business conduct increases trust in our company and improves relationships with key stakeholders.

In the Novo Nordisk Way , we outline expectations for employee behaviour by stating that ‘we never compromise on quality and business ethics’ (Essential 10). This is supported by our Business Ethics Code of Conduct and Business Ethics Compliance Framework for how to operate.

We focus on complying with all local and international anti-corruption laws, principles, standards and codes (including codes developed by patient organisations) and ensuring transparency in all interactions.

We have a Global Business Ethics Compliance programme to ensure compliance with all relevant anti-corruption laws and to work against corruption. The programme has seven elements:

• Implementing business ethics policies and procedures
• Designating a compliance officer and compliance committees
• Conducting effective training and education
• Developing effective lines of communication
• Conducting internal monitoring and audits
• Enforcing standards through well-publicised disciplinary guidelines
• Responding promptly to detected problems and undertaking corrective action

Personal data protection and privacy
As a healthcare company, we handle large volumes of personal data, including information on participants in clinical trials, human biosample donors, patients and healthcare providers reporting safety concerns, and our employees. We store and transfer personal data in and across different jurisdictions on a global level. Our Code of Conduct and Business Ethics Compliance Framework are the basis for our global Personal Data protection Compliance Programme. Together, they set the minimum global standards for how we handle and protect personal data.

We always comply with any stricter local legal requirements for protecting personal data. We recognise that domestic law may not adequately protect the right to privacy in some jurisdictions. Where there is a conflict between the national law and the internationally recognised human rights principle of privacy, we always seek to make a responsible decision about how to handle personal data.

Our global Personal Data Protection Compliance Programme, including policies, training, and oversight mechanisms, is developed and maintained centrally, but each business area and its management are responsible for ensuring that their operations are in compliance with our internal requirements and applicable law.

Our Personal Data Protection Compliance Programme conducts cross-organisational reviews of risk to privacy in key functional areas to identify where we can reduce data collection and mitigate the highest risk to data subjects.  The Personal Data Protection compliance programme continuously assesses risks and trends and monitors national and international laws to ensure continued compliance.

Our actions under the Personal Data Protection Compliance Programme include:

• Establishing standards detailing how employees must protect personal data;
• Training employees on how to comply with the standards;
• Monitoring and auditing to ensure that the standards are effectively implemented;
• Investigating potential non-compliance and imposing disciplinary sanctions as appropriate;
• Maintaining processes to allow individuals to request access, correction, and deletion of their personal data, and to object to processing of their data
• Maintaining processes to promptly respond to personal data breaches

Performance
Annual training in business ethics is mandatory for all employees, including all new hires. In 2021, 98% of employees completed and documented their training, with the remaining 2% missing mainly due to employees being on leave. In 2021, 37 business ethics reviews were completed with 129 findings, compared with 32 reviews with 107 findings in 2020. Consolidated findings are reported to our Executive Management and the Audit Committee. Group Internal Audit assesses that the level of business ethics compliance is sound. Management action plans and closure of findings progressed as planned and there were no overdue management actions or findings at the end of the year. In 2021, data ethics principles were improved and will be implemented through policies and trainings across the organisation in 2022. We further strengthened the global integration of data protection and human rights risks in the business ethics risk management process.

Our Responsible Sourcing programme aims to ensure that our social and environmental responsibility is reflected throughout the supply chain.

The programme is based on our commitment to the UN Global Compact and the UN Guiding Principles on Business and Human Rights in our supply chain.

With more than 60,000 suppliers across the globe, our expenses with suppliers accounts for more than a third of our total sales revenue. It is vital that we understand potential risks to responsible business conduct across our global supply chain and take necessary steps to mitigate risks.

Our Responsible Sourcing Standards for business partners have been implemented globally. Our Standards articulate what we mean by responsible sourcing and make clear our expectations to our suppliers on responsible business conduct within human rights, labour, health & safety, environment and anti-corruption. Our Standards build on international standards and are aligned with the Pharmaceutical Industry Principles for Responsible Supply Chain Management.

Novo Nordisk's Responsible Sourcing Standards for business partners are available in the following languages:

• Danish (PDF) | English (PDF) | German (PDF) | French (PDF) | Spanish (PDF) | Chinese (PDF) | Japanese (PDF) | Portuguese (PDF) | Russian (PDF)

Our other declarations, disclosures and statements include:

• California Transparency in the Supply Chain Act

For our declaration on the California Transparency in the Supply Chain Act, visit our US website.

• Conflict Minerals Disclosure

Read our Conflict Minerals Disclosure 2022

Read our Conflict Minerals Disclosure 2021

• UK Modern Slavery Act

Read our statement on the UK Modern Slavery Act

Performance
The number of audits concluded in 2021 increased by 43% compared with 2020. The increase represents an improved ability to conduct audits of suppliers although the effects of COVID-19 continue to limit travel and access to suppliers' facilities. One critical finding regarding credibility of certificate of analysis has been issued during a qualification audit in 2021. Consequently, Novo Nordisk has decided not to use the supplier in question.

Every day, millions of people rely on the quality and safety of our products.

All medicines have potential side effects as well as benefits. We routinely monitor the safety and quality of all our products. This includes review of safety data from clinical studies and review of side effects and technical complaints received on marketed products. By monitoring quality and safety information on our products we can take due and appropriate actions to safeguard patient safety if needed.

We have in place a Quality Management System to ensure that we adhere to international and local legislation and that safety information is handled in the same way no matter in which country the patient lives.

Our Global Safety team has a pharmacovigilance system in place ensuring that the necessary means for collection and notification of any safety data are in place.

Prior to any clinical investigation of a new pharmaceutical product or medical device, a safety committee with members from all relevant functional areas is established. This committee will exist throughout the product or device’s life cycle. It is a multi-disciplinary team providing assessments of safety data, for a pharmaceutical product or medical device in development or on the market.

Further procedures ensure we can react promptly and adequately if one of our products on the market, or used in clinical trials, is suspected of being affected by a significant product defect, such as recalling affected products.

We are committed to patient safety and want to make it easy for patients to get in contact with us, if they have a complaint or want to report a side effect. Therefore, we have established easily accessible online complaint reporting directions with contact information in local language.

Counterfeit products
Counterfeit products pose significant and potentially life-threatening risks to the health of patients. Such products may lack active ingredients so patients do not receive the treatment they expect and need, or they may contain other ingredients that could pose a safety risk.

To ensure patient safety, we have been implementing a comprehensive anti-counterfeit programme. A cross functional Anti-Counterfeit Working Group, chaired by the head of our Customer Complaint Centre, ensures vigilant risk assessment and implementation of an Anti-Counterfeit Product strategy.

We have an ongoing international collaboration with regulatory bodies, scientific and trade organisations, law enforcement agencies and other stakeholders to investigate counterfeit products and to influence legislation regarding new anti-counterfeit measures.

Those found guilty of producing or/and distributing counterfeit Novo Nordisk products are given fines and/or custodial sentences. China, as a result of lobbying and official intervention, has increased the length of sentences for counterfeiting.

We are a member of the Pharmaceutical Security Institute (PSI), which on behalf of the approximately 30 largest pharmaceutical companies, collects information and coordinates investigations into counterfeit products worldwide.

We conduct regular reviews of risks through information exchange with external collaborators. The investigation of suspected counterfeit cases is reported via our affiliates or authorities. Monthly internal counterfeit surveillance reports are reviewed by key specialists and management.

Our Quality Management System identifies and investigates alleged occurrences of counterfeited Novo Nordisk products. In China, we work with local investigation firms to perform market searches to help health authorities track down and seize counterfeit products. Outside China, we conduct investigations of suspected counterfeit products based on risk analysis and take legal action against those involved in the counterfeiting of our products.

Recognising that low awareness and under-reporting are known issues in many countries, we provide internal video training for our affiliates globally.

In China, our proactive approach including collaboration with and training of local authorities, and scouting for counterfeit products and reporting these to local authorities has enabled us to keep counterfeit products at a relatively lower level.

Currently, the main products being counterfeited are NovoFine ^® in China and Norditropin ^® sold via the internet or in fitness centres.

Performance
Novo Nordisk had one product recall in the US in 2021 due to disbursement of product samples without proper temperature monitoring.

In 2021, as in 2020, Novo Nordisk had no failed inspections among those resolved at year-end. However, a contract manufacturer filling syringes for Wegovy ^® failed an inspection causing disruption in the supply of Wegovy ^® . During 2021, 97 inspections of Novo Nordisk were conducted, compared with 77 in 2020. At year-end, 86 inspections were passed and 11 were unresolved, as final inspection reports had not been received or the final authority acceptance was pending, which is normal. Follow-up on unresolved inspections continues in 2022.

The Novo Nordisk Way is a set of guiding principles which underpins every decision we make. We use a unique, systematic approach known as facilitation to ensure that everyone lives up to the Novo Nordisk Way. Any issues identified during a facilitation are addressed locally, and consolidated insights are shared with Executive Management and the Board of Directors. The Novo Nordisk Way also underpins our performance management and incentive programmes.

Performance
In 2021, a total of 34 units were facilitated and more than 1,600 employees were individually interviewed. In addition, feedback on those units was collected from approximately 500 stakeholders.

Overall, the 2021 process continues to show a good level of adherence to the Novo Nordisk Way. 5 units were found to be in breach of one or more of the Novo Nordisk Essentials . The Essential with the strongest performance continues to be Essential 1 (We create value by having a patient-centred business approach) and Essential 10 (We never compromise on quality and business ethics. In 2021, partly driven by the focus on strengthening the culture journey, significantly more findings were issued related to Essential 2 (We set ambitious goals and strive for excellence) and Essential 7 (We focus on personal performance and development).

As a leading global healthcare company, we engage with a variety of stakeholders, including public officials, healthcare professionals, patient organisations and business partners. In all our interactions, our first priority is to live up to our responsibilities and all regulatory requirements.

Our policy on transparency is clear - we will be transparent and accountable for how we operate and the transactions that take place when and where we work.

This is a part of Novo Nordisk’s company values expressed in the Novo Nordisk Way and  in our Business Ethics Compliance Framework, and how we earn and retain trust and confidence.

The Novo Nordisk reputation score among key stakeholders (i.e., the informed general public, people with diabetes, people with obesity, healthcare professionals and diabetes specialists) is an indicator of the extent to which we live up to society’s expectations. It is the emotional bond that stakeholders feel towards Novo Nordisk and it is measured across Esteem, Admiration, Trust and Feeling dimensions.

Performance
We achieved a strong reputation score of 82.6 points in 2021 measured on a scale of 0-100. As the only company among our selected peers, Novo Nordisk enjoys a strong (i.e., above 80 points) reputation for Products & Services, which is the most important driver of reputation across all stakeholder groups, and thus the key driver of the positive overall result.

Currently, it is not possible to examine the complex interactions in a living organism solely through the use of cell cultures and tissues. Hence, research using living animals is essential for all pharmaceutical companies in the discovery, development and production of new pharmaceutical and medical products.

We recognise that not all research using animals can be replaced in the foreseeable future and consider it our responsibility to actively support the principles of the 3Rs (Reduce, Refine and Replace research using animals, Professor William Russell and Rex Burch, 1959) internally and externally.

Animal welfare is our highest priority. We have a centralised strategic department that contributes to internal awareness and education as well as ensure continued integration of the 3R considerations in our decision-making processes. Furthermore, the department engages in dialogues and partnerships with our key stakeholders.

When animals are necessary for research, their welfare is given high priority and attention in several ways. Not only when they are being tested, but also when they are housed.

Our state-of-the-art housing standards consider the physiological and ethological (behavioural) needs of the animals. We have successfully been able to implement the standards for all animals housed at our facilities.

The design of our renovated facilities was made in close collaboration with The Danish Animal Welfare Society and with valuable input from many internationally recognised experts within animal welfare, as well as input from the employees working every day with the animals, especially the animal caretakers.

For additional information about animal ethics, click here .

To read about our commitment to the Marseille Declaration on animal housing and use, click here

Performance
The number of animals purchased for research in 2021 decreased by 4.3% compared with 2020 due to reduced usage of mice, rats and other rodents. The overall development reflects the changes in stages of the different research projects. The reduction in the number of rodents purchased reflects Novo Nordisk's continuous focus on reducing the number of animals per research project. 75% of the animals purchased were rodents and 22% were fish.