Creating a Culture of Citizenship Ethics and Compliance
More than 90 percent of our Latin American employees have participated in an innovative workshop we call The Positive “No,” a program designed to remind employees that saying “no” in a positive manner not only helps avoid ethical conflicts, but actually strengthens customer and partner relationships.
Abbott’s Code of Business Conduct, our basic guidelines and requirements for ethical behavior, is available in 36 languages.
Our employees both inside and outside the U.S. must comply with all local policies, codes and laws. Here, marketing and sales personnel in Mumbai participate in ethics and compliance training.
Our distinctive board game, Road Signs, challenges our Eastern European employees to demonstrate their knowledge of Abbott policies and products.
Abbott is committed to doing business in a responsible manner and to building trust with all our stakeholders. We work every day to earn that trust, making sure that our approximately 91,000 employees understand the importance of the actions and decisions they make and the manner in which they conduct themselves. We are guided by the Abbott Promise for Life, by company policies and procedures and by a clear understanding of applicable legal and regulatory requirements. Our ethics and compliance program and strategies work to the benefit of Abbott and our shareholders by safeguarding our company’s reputation and enhancing trust.
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Business Ethics at Abbott
At Abbott, we are committed to meeting high ethical standards and to complying with all applicable local, national and international laws wherever we do business. Our ethical standards and commitments are embodied in our Abbott Promise for Life, a statement that describes – for our customers, our communities, our shareholders and all other stakeholders – what we believe, what we value, and what we strive to deliver in our day-to-day work. For the people of Abbott, the Abbott Promise is a compass that guides our actions and decisions, ensuring that we live up to the high expectations we set for ourselves so we can better serve our stakeholders. It challenges us to continually improve and inspires us to always aim higher.
Effective Compliance Program
Abbott’s ethics and compliance program requires not just adherence to applicable laws and regulations, but in many cases goes beyond them, in a manner consistent with our commitment to honesty, fairness and integrity. Ours is an integrated, company-wide program that is organized around the seven elements of effective compliance as set forth in the voluntary “Compliance Program Guidance for Pharmaceutical Manufacturers,” published by the Office of Inspector General, U.S. Department of Health and Human Services. These seven elements are:
- Written Standards
- Effective Lines of Communication
Our program also requires compliance with many voluntary industry guidelines, as noted below. Our approach to the seven key elements of effective compliance is as follows:
The Chief Ethics and Compliance Officer (CECO) is responsible for the management and operation of the Office of Ethics and Compliance (OEC) and the development and enhancement of the compliance program. The CECO makes regular reports regarding compliance matters to the Chairman of the Board and the Chief Executive Officer, senior level leadership and Abbott’s Board of Directors and committees. The Business Conduct Committee (BCC) consists of senior-level leadership and is chaired by the CECO. The BCC is accountable directly to the Chairman of the Board and the Chief Executive Officer and was established to assist in the implementation of the compliance program. The BCC holds periodic meetings to discuss matters including the legal and regulatory environment, risk areas and best practices, as well as modifications to the compliance program on the basis of such evaluation. OEC staff provides dedicated support to each of Abbott’s businesses.
Outside the United States, our Affiliate Compliance Program is managed by local Affiliate Compliance Committees, which are composed of the General Manager and other top executives representing all of Abbott’s businesses within a country. The Affiliate Compliance Committees are responsible for the day-to-day function of the compliance program, including monitoring of compliance, providing awareness of and training for the program, revising policies and procedures, and providing guidance to local employees. The committees also meet on a regular basis to discuss emerging issues and work with the International Ethics and Compliance organization as new programs initiated by the OEC are rolled out. Compliance professionals are located throughout the world and provide oversight and guidance to the Affiliate Compliance Committees.
The Abbott Code of Business Conduct, published in print and online in 36 languages, sets forth our basic guidelines and requirements for ethical behavior. Abbott employees read and certify adherence to our Code annually. Our Code states clearly that Abbott does not tolerate illegal or unethical behavior in any aspect of our business. It emphasizes the importance of ethical and honest conduct, adhering to Abbott’s policies and procedures, treating confidential information appropriately, avoiding conflicts of interest and maintaining Abbott’s books and records with accuracy and integrity. Further, it requires our employees to ask questions or report any concerns.
Policies and Procedures
In addition to our Code, we adopt policies and procedures that guide employees as they conduct their day-to-day activities. They encompass relevant laws and regulations, including food and drug laws and laws relating to government health care programs. They also take into account industry best practices, including provisions of the International Federation of Pharmaceutical Manufacturers & Associations (IFPMA) Code of Pharmaceutical Marketing Practices, the updated Pharmaceutical Research and Manufacturers of America (PhRMA) Code on Interactions with Healthcare Professionals and the updated Advanced Medical Technology Association (AdvaMed) Code of Ethics on Interactions with Health Care Professionals, as well as other applicable industry codes. We regularly update our policies to incorporate changes to the law and industry codes, including rules regarding gifts, meals and education we provide to health care professionals.
A growing number of state laws in the United States require greater transparency in the relationships between our industry and individuals and entities involved in providing health care. These laws impose various combinations of code of conduct restrictions on activities involving health care professionals and health care organizations and tracking and reporting of payments and transfers of value (such as meals) provided. Abbott complies with all such laws, which currently exist in California, the District of Columbia, Massachusetts, Minnesota, Nevada, Vermont and West Virginia. Abbott also is preparing to comply with the federal Sunshine Act, for which tracking will begin in 2012.
Effective Lines of Communication
Creating an environment where employees can raise questions and concerns helps us advance our commitment to ethical behavior. We have established systems and processes for employees to ask questions and report suspected or actual violations of our Code, policies and procedures. We offer a number of resources to employees, such as our Ethics and Compliance Helpline, a telephone and Web-based hotline available 24 hours a day, seven days a week. Employees also may contact the OEC or the CECO directly.
In 2011, we received approximately 720 inquiries and allegations. All allegations are analyzed and corrective actions are taken where necessary, including terminating employees or supplier relationships. When appropriate, we report information about breaches of our Code to senior management. The OEC also creates opportunities to engage in face-to-face interactions with employees by participating in national and regional sales meetings and local site meetings. Issues also are highlighted on our OEC intranet site and through other targeted communications vehicles.
Training and education programs for employees increase their awareness of our Code’s precepts and the legal and ethical implications of their actions and behaviors. Abbott ethics and compliance officers work with our local commercial teams throughout the world to help them conduct trainings and education programs that help ensure compliance and strengthen Abbott’s reputation as a responsible corporate citizen while enhancing relationships with customers and other stakeholders.
For example, employees in the United States, Puerto Rico and Latin America participate in our Legal and Ethics Resource Network program, a Web-based training system designed to increase awareness of the legal and ethical implications of business decisions. More than 37,500 employees completed these training programs in 2011. Another successful approach has been the use of interactive ethics challenge games, in which local employees meet face-to-face with OEC representatives to ask questions and discuss company policies.
Ethics and compliance training is a part of Abbott’s culture wherever we operate. In Romania, for example, employees are constantly reminded of compliance rules and principles through a game called Compliance Made Fun! Employees there receive a weekly email setting forth a compliance “theme of the week,” which is followed by an emailed quiz. Prizes are awarded for employees who score the highest, with extra credit available to those willing to dare colleagues to compete with them in the contest. In other Eastern European nations, Abbott employees are invited to play Road Signs, an ethics and compliance board game that tests their knowledge of Abbott policies and products.
Additionally, more than 90 percent of our Latin American employees have participated in an innovative workshop we call The Positive “No.” Begun in 2009, Positive “No” helps employees learn and practice assertive communication skills that clarify expectations of customers and other business partners. The program reminds employees that saying “no” in a positive manner not only helps avoid ethical conflicts, but actually strengthens customer and partner relationships by enhancing the reputation of the company and its people. The Positive “No” program has been awarded an Abbott Chairman’s Award, and we plan to replicate it outside Latin America.
Abbott employees are expected to adhere to our Code as a condition of their continued employment. Any Abbott employee who violates our Code, or any policy or procedure, is subject to appropriate disciplinary action. Any Abbott employee who fails to report a violation of Abbott policy or procedure of which he or she is or should have been aware may also be subject to disciplinary action. Abbott does not tolerate retaliation against anyone who makes a good-faith report regarding a violation or potential violation of our Code, policies or procedures. These guidelines are well publicized and enforced.
The OEC utilizes results from internal investigations, internal audits and internal monitoring programs to assess the effectiveness of, and identify areas for improvement in, the compliance program and relevant business practices. In addition, we consider the external environment, including government investigations, settlements, industry codes and government guidance to identify new opportunities to enhance the compliance program.
Results of investigations, audits and monitoring are communicated to the appropriate OEC staff and business leaders. When an area for improvement is identified, the OEC partners with the business to implement corrective actions.
Note: All data in the Global Citizenship section reflects activities prior to the separation of Abbott and AbbVie on January 1, 2013.