We are fair and honest
We operate fairly and honestly with all of our stakeholders and business partners and expect that they will do the same. Our books, records and financial statements must be honest, accurate, objective, complete and timely in order to ensure we make sound business decisions.
We Communicate Transparently
We are transparent and communicate truthful information in a manner that is not misleading. Our promotional, medical and investor information is appropriately vetted and approved prior to use.
Maintaining Strong Business Partnerships
We treat all our business partners fairly and honestly, and we expect them to act with integrity. In dealings with Biogen, suppliers and business partners must follow the Code.
MAKE SURE YOU
- Consider both good value for money or fair market value and industry standards when choosing suppliers
- Disclose any potential conflicts of interest
- Charge all payments to the business entity or project benefitting from the payment
- Only sign off on transactions once you fully understand them and are certain that they comply with Company policies (See Approver responsibilities via Global Approval Policy-107 section 1.0)
- Only approve payments once you fully understand the invoice and agree with the invoice amounts
- Only make payments in accordance with the payment terms as defined in the contract, statement of work or invoice
- Ensure all third-parties (e.g. vendors, consultants, HCPs, distributors, etc.) engaged by or on behalf of Biogen are subject to appropriate due diligence screening before entering into any business relationship
- Communicate any issues that are identified to appropriate Biogen personnel, including HR, Legal, Corporate Compliance, Finance, or the helpline
WATCH OUT FOR
- Improperly documented payments. All payments must be made in accordance with negotiated agreements and invoices that fully and accurately set forth the nature and purpose of the transaction
- Payments to business entities that are not listed on the original sales agreement or sales invoice
To learn more
- Global Antibribery and Anticorruption Policy
- Conflicts of Interest and Outside Activities Policy
- Global Contract Review Policy
- Global Travel and Expense Policy
- Global Approval Policy
- Global Purchasing Policy
- Global Grants, Donations and Sponsorships Policy
- Global Third-Party Due Diligence Screening SOP
For all policies refer to the iNet
Business Intelligence and Confidential Information
Information about competitors is a valuable asset in today’s business environment. We will never engage in deception to obtain information. We also need to be careful when accepting information from third-parties. We should know and trust their sources and be sure that the knowledge they provide is not protected by trade secret laws or confidentiality agreements. When Biogen employs former employees of competitors, we recognize and respect the obligations of those employees not to use or disclose the confidential information of their former employers.
When engagement with third-parties involves sensitive or confidential information ensure an agreement covering confidentiality is in place.
MAKE SURE YOU
- Obtain competitive information only through legal and ethical means
- Respect the confidentiality obligations of others
- Require third-parties to respect our information
WATCH OUT FOR
- New employees who retain papers or computer records from prior employers in violation of laws or contracts
- Using confidential information without appropriate approvals
- Using job interviews as a way of collecting confidential information about competitors or others
- Information from third parties – confirm that it was obtained properly
Questions & Answers
I am a manager and one of my new employees who recently joined Biogen from a competitor has confidential information from her previous employer. She says she plans to use it to our advantage. Should I just ignore this and let her do it?
No. If an employee retains and uses such information, it is not appropriate and can result in legal action by the competitor. You must report this to the Legal department for appropriate action.
Accurate and Timely Disclosures and Business Records
Our Company is subject to extensive and complex reporting requirements. Our operations must comply with all applicable regulatory, accounting, financial, tax and other rules and regulations of the jurisdictions in which we operate.
Business partners, government officials, investors and the public rely on the accuracy and completeness of our financial reports, business records and what we tell them. All of our financial records and accounts, and financial statements must be clear and complete, maintained in reasonable detail, and appropriately reflect our Company’s transactions and activities. This includes our financial records and operational data such as cost and production data, expense reports and employee records. Accurate and complete information is also essential to us as a basis for sound decision-making.
The Company’s filings with the Securities and Exchange Commission, as well as other public disclosures by or on behalf of our Company, must be fair, complete, accurate, timely, and understandable. Our accounting and financial reporting practices must also comply with applicable generally accepted accounting principles and other criteria, such as local statutory reporting and tax requirements. Depending on their positions with the Company, employees may be called upon to provide necessary information to assure that the Company’s filings and public communications meet these standards. The Company expects employees to take this responsibility seriously and to promptly provide current, accurate and complete answers to inquiries related to the Company’s public disclosure requirements.
Managing Our Records
Each of us is responsible for information and records under our control so we need to be familiar with the records management procedures that apply to our jobs.
Biogen has a records and information management policy and procedures to ensure that our financial records and information are appropriately maintained, stored, secured and destroyed in accordance with our business needs and in compliance with applicable laws and regulations.
We maintain paper and electronic records for as long as required by our policies and law and our records are organized so that they can be located and retrieved when needed. Documents should only be destroyed in accordance with our Records Retention and Disposition Schedules policy, and never in response to or in anticipation of litigation, an investigation or an audit. Do not hesitate to contact Enterprise Records and Information Management or the Legal department if there is any doubt about the appropriateness, or method, of record destruction.
MAKE SURE YOU
- Create business records that accurately reflect the truth
- Record transactions as prescribed by our system of internal controls
- Provide timely and candid financial disclosures and forecasts to management without knowingly omitting or misrepresenting relevant or material information
- Write carefully and clearly in all your business communications, including emails
- Write with the understanding that someday what you write may become a public document
- Manage and secure records based on the sensitivity of the information they contain
- Always comply with instructions from the Legal department to retain records pursuant to a litigation or investigation hold
- Understand and follow our Written Standards regarding recording keeping
WATCH OUT FOR
- Actions or directions to others that make our financial statements inaccurate or misleading
- Actions that might interfere in any way with the auditing of records
- Destruction of records that must be preserved
In financial reporting, complying with external rules and regulations and internal policies is our focus and first priority. It forms the foundation for our value-added work of providing accurate and meaningful information to facilitate informed decision-making.
To learn more
Questions & Answers
At the end of a reporting period, my supervisor asked me to record additional expenses even though the related work has not yet started. I agreed to do it, mostly because I didn’t think it really made a difference since we were all sure that the work would be completed in the next quarter. Did I do the right thing?
No, you did not. Costs must be recorded in the period in which they are incurred. The work was not started and the costs were not incurred by the date you recorded the transaction. That is a misrepresentation and, depending on the circumstances, could amount to fraud.