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.

Novo Nordisk is disclosing direct and indirect payments (transfers of value) in line with the EFPIA Code of Practice. Each affiliate has disclosed according to local EFPIA association requirements. The EFPIA Self Certification Letter for 2021 is signed by Lars Fruergaard Jørgensen, Presiden and Chief Executive Officer, Novo Nordisk.

Novo Nordisk's Self Certification Letter (PDF)

Click here to see our locations and access our European affiliate disclosures according to local EFPIA association requirements.

Quick links to Novo Nordisk affiliates' websites in European region:

Austria , Belarus , Bulgaria, Bosnia , Bulgaria , Croatia , Cyprus
Czech Republic , Estonia , Finland
Germany , Greece , Hungary , Ireland
Italy , Latvia , Lithuania , Macedonia , Malta ,
Norway , Poland , Russia , Serbia ,
Slovakia , Slovenia , Spain , Sweden
Switzerland , Ukraine , United Kingdom

The Modern Slavery Acts require companies in scope to produce a statement which must set out what steps they have taken during the financial year to ensure that modern slavery is not occurring in their supply chains or in their own organisations.

The Acts require companies to be transparent about their actions in addressing and preventing modern slavery and expects continuous improvement year on year. The Acts require that companies annually publish a statement on their external website with a link to a prominent place on their homepage.

Read our statement on Modern Slavery Acts:

2017 2018 2019 2020 2021

We must collaborate with many parties on our mission to improve treatments for serious chronic diseases, such as diabetes, obesity, haemophilia and growth disorders.  This includes providing as much information as we can to healthcare professionals, institutions, and patients about proper use of the medicines and the drug delivery systems we manufacture.

Collaborations with physicians, research organisations, healthcare institutions and patient organisations help us understand and identify unmet medical needs, drive innovation and develop new medicines and enhance the quality of health education.

We meet all compliance requirements for disclosure of our financial relationships related to our collaborations with the medical community, as spelled out by relevant decrees and industry guidelines, as well as local laws, including:

  • Danish Medicines Act
  • European Federation of Pharmaceutical Industries and Associations [EFPIA]
  • ‘Transfers of value from Pharmaceutical Companies to Healthcare Professionals and Healthcare Organisations’
  • French National Councils
  • ‘Bertrand Act’ or ‘French Sunshine Act’
  • Japan Pharmaceutical Manufacturers Association
  • ‘Transparency Guideline for the Relation between Corporate Activities and Medical Institutions’
  • United Kingdom, Prescription Medicines Code of Practice Authority
  • ‘The ABPI Code of Practice for the Pharmaceutical Industry’
  • United States Patient Protection and Affordable Care Act Section 6002
  • ‘Open Payments’ or ‘Sunshine Act’

We believe that transparent disclosure of financial relationships with healthcare professionals and institutions with whom we collaborate is very important to maintaining trust-based relationships and earning the public's trust.

Our position on conflict minerals
We are committed to conducting our business in a financially, environmentally and socially responsible way. This is our Triple Bottom Line principle, which we apply in order to be a sustainable business. We conduct our business with respect for human rights and in compliance with all applicable laws and fair labour practices.

  • We support the goal of ending violent conflict in the Democratic Republic of Congo and adjoining countries that is partially financed by the exploitation and trade of conflict minerals.
  • We will not knowingly procure any of the specified metals if they originate from the DRC and adjoining countries unless they are certified as conflict free.
  • We expect our suppliers to source materials responsibly and commit to utilise a supply chain that only sources from legitimate, conflict-free mines.
  • To ensure compliance with these requirements, we request any suppliers of conflict minerals, or products incorporating conflict minerals, to conduct the necessary due diligence of their own supply chain and provide  verification that the materials used in the products they supply to Novo Nordisk are Democratic Republic of Congo conflict free.

Our conflict minerals disclosure
Conflict minerals are natural resources extracted in a conflict zone such as the Democratic Republic of Congo (DRC) or in adjoining countries, and which are often sold to fund regional conflicts.

The U.S. Securities and Exchange Commission requires companies whose shares are traded on U.S. stock exchanges to annually disclose whether the products they manufacture or contract to manufacture contain conflict minerals that are necessary to the functionality or production of such products that were sourced from the DRC or adjoining countries.

The conflict minerals covered by this rule are:

  • Cassiterite (the metal ore most commonly used to produce tin)
  • Columbite-tantalite (coltan) (the metal ore from which tantalum is extracted)
  • Wolframite (the metal ore used to produce tungsten)
  • Gold

Read our conflict minerals disclosure report (download PDF)

Our conflict mineral due diligence process
We manufacture or contract to manufacture a limited number of products containing conflict minerals that are necessary to the functionality or production of such products. In all instances where this is the case, we certify that those conflict minerals are not sourced from the Democratic Republic of Congo or adjoining countries. This certification is based on a supply chain country-of-origin inquiry, described in more detail below.

We utilise a four-step supply chain country-of-origin inquiry process:

  • We work internally to identify all our products that contain conflict minerals, and to identify the suppliers of those products and/or suppliers of components or raw materials for such products.
  • We contact suppliers of products, components, raw materials that contain conflict minerals in writing and ask that they complete a survey modelled on the Responsible Business Alliance (RBA) and Global e-Sustainability Initiative (GeSI) joint conflict minerals due diligence template. Suppliers are required to provide a written response indicating whether a) any of the products they supply to Novo Nordisk contain conflict minerals necessary to their production or functionality, b) whether any such conflict minerals are sourced from Covered Countries, and c) if so, whether the suppliers can certify the conflict minerals are DRC conflict free within the meaning of the conflict minerals rule.
  • We review those responses to determine whether there are facts, circumstances or red flags of any kind that could give reason to question a supplier’s response or certification, or that otherwise merits a more detailed due diligence process.
  • To the extent necessary we make additional inquiries or perform additional reviews in order to resolve any such facts, circumstances or red flags.

Partnerships and collaboration with patient organisations are essential to our mission of driving change to defeat diabetes and other serious chronic diseases. These interactions provide us with valuable insights into how the lives of people with chronic diseases are affected and the barriers they encounter to living their life to the full.

In addition, assistance from pharmaceutical companies like ours helps patient organisations do  their work in support of patients and their caregivers.

We collaborate with patient organisations in an open and transparent manner to ensure respect of their independence and integrity and adherence with our own ethical standards. Our support is based on written agreements that clearly state the purpose of the support as well as the amount and a description of indirect support and any significant non-financial support.

National collaboration with patient groups
Lists of national collaborations with patient organisations can be found at the Novo Nordisk affiliates’ websites.

Quick links to Novo Nordisk affiliates' websites in European region:

Austria , Belgium (fr), (nl) , Bulgaria , Croatia
Czech Republic , Denmark , Estonia , Finland
France , Germany , Greece , Hungary , Ireland
Italy , Latvia, Lithuania, Netherlands, Norway
Poland, Portugal , Serbia , Slovakia , Slovenia
Spain , Sweden , Switzerland , Turkey , United Kingdom

Disclosure from Novo Nordisk affiliates in the European region with no website

FYROM - Macedonia

International collaboration with patient groups
For list of collaborations with international patient organisations, select one of the links below: