We do not offer or provide improper incentives, kickbacks, or bribes to win business, to influence a business or prescribing decision, or to advance our interests with government authorities. In particular, our interactions with healthcare professionals, government entities, government employees, and others must be legitimate and never to obtain an improper advantage or to improperly influence or encourage a decision by them.

Cooperating with Regulators

We will always comply with relevant laws and regulations and cooperate with government agencies, law enforcement officials and investigators. If you receive any inquiries from government regulators or officials, you should contact the Legal department immediately and wait for their guidance before responding to any such request. When notified of an external investigation, we will take prompt action to preserve documents that may be relevant, and respond to requests for information in an honest and timely manner.

We will promptly review all reports of misconduct and undertake investigations to gather additional information. All employees are expected to cooperate fully and truthfully with investigators. Never mislead an investigator and never alter or destroy records in response to an investigation. Other important points you should know about the investigations process include:

  • The facts of the case will typically be developed through interviews and document review
  • Depending on the nature of the investigation and the matters at issue, you may be instructed by the investigators or the Legal department not to discuss any aspect of the investigation
  • If misconduct is discovered, the Company will take whatever corrective or disciplinary action is necessary to address the situation and prevent a recurrence
  • Questions & Answers

    Question:

    Why are we expected to cooperate with ethics and compliance investigations? I would rather not get involved.

    Answer:

    Your assistance is important and it is your responsibility to cooperate. When the Company conducts an investigation, it is reviewing a possible violation of the Code, Biogen policies, or relevant legal requirements. If employees do not cooperate, it is impossible to get all the facts and take the appropriate corrective actions. Withholding information or knowingly giving false or misleading information is a serious violation of our duties as employees, and could result in disciplinary action, including termination.

  • Avoiding Bribery and Corruption

    We do business with honesty and integrity and comply with all applicable ethical and legal standards. The ]laws of all countries in which we operate prohibit bribing government officials and many laws have a global reach.  There are additional laws that address bribes paid to private individuals. Due to the complexity of anti-corruption and bribery laws worldwide, it is important that employees be aware of Company policies and ask questions if they have any doubts about the proper course of action. If you have questions, contact your supervisor or any of the resources listed in this Code. 

    We are responsible for third parties acting on our behalf. We perform due diligence and carefully monitor our business partners and require them to operate in compliance with our Code and our standards.

    MAKE SURE YOU

    • Never offer money or any item of value to improperly influence a business decision
    • Never make payments to improperly influence a government official
    • Note: “Government official” applies not only to politicians and civil servants but also to employees of state-owned enterprises, such as physicians employed by state-run hospitals
    • Ensure all third-parties (e.g. vendors, consultants, HCP’s, 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 Legal, Corporate Compliance, Finance or the helpline

    WATCH OUT FOR

    • Unethical or suspicious conduct by a supplier or business partner. If you have concerns, contact management. We will take appropriate action
  • To learn more

    • Global Antibribery and Anticorruption Policy
    • Global Contract Review Policy
    • Global Purchasing Policy
    • Global Travel and Expense Policy
    • Global Approval Policy

    For all policies refer to the iNet

  • Questions & Answers

    Question:

    A research physician tells you that he always makes sure Biogen drugs “look good” in the clinical trials he runs. He says he knows Biogen appreciates it because the Company has contracted with him to do multiple trials. What should you do?

    Answer:

    The issue should be raised to your supervisor, Compliance, Legal or the Helpline.  Although the physician delivers good results, the Company may have failed to pick up on the physician’s practices that could taint the trials, affecting patients, our product approval, and our reputation. If made aware of this, the Company would investigate and take appropriate action.

  • Facilitation or Expediting Payments

    Facilitation or expediting payments are modest amounts of money paid as an unofficial fee to low level government employees to speed or initiate the performance of routine service. They are prohibited by our policies. If you are solicited for a facilitation or expediting payment, contact the Legal department immediately.

  • Questions & Answers

    Question:

    Sometimes when I’m traveling, I see practices that I consider inappropriate, but they are common practices in the country I’m visiting. What should I do if I’m asked to provide what I consider to be a bribe but what the locals think of as a common business courtesy?

    Answer:

    No matter where you are, our policy applies. 

  • Fair Business Practices

    We believe in free and open competition. We never look to gain competitive advantages through unethical or illegal business practices. We do not enter into agreements with competitors to engage in any anti-competitive behavior, including setting prices or dividing markets. We do not engage in unfair or deceptive acts or practices, such as false or misleading advertising, or other misrepresentation.

    MAKE SURE YOU

    Understand that antitrust and competition laws are complex and compliance requirements will depend on the circumstances.

    The following activities should be avoided:

    • Collusion
      When companies secretly communicate or agree on how they will compete. This could include agreements or exchanges of information on pricing, or allocations of markets
    • Bid-rigging
      When competitors manipulate the bidding process. This may include comparing bids, agreeing to refrain from bidding, or knowingly submitting noncompetitive bids
    • Predatory Pricing
      When a company with market power sells a product or service below cost so as to eliminate or harm a competitor. Never share our competitive information with our competitors

    WATCH OUT FOR

    • Formal or informal conversations with competitors about sensitive business information
    • Use of non-public information about competitors received from new hires or interviewees
    • Conversations with competitors that could be perceived as limiting competition. If such a conversation begins, leave the meeting immediately and report it to the Legal department
  • To learn more

    • Global Competition Law Policy

    For all policies refer to the iNet

  • Questions & Answers

    Question:

    received sensitive pricing information from one of our competitors. What should I do?

    Answer:

    Contact the Legal or Compliance departments without delay and before any further action is taken.

  • International Trade

    We comply with the import/export control laws, trade restrictions and anti-boycott laws of the United States and other countries, and we expect our business partners to do the same.  You should make sure that you know and comply with these laws, and applicable company policies and procedures, when engaging in an international transaction or when releasing certain types of technical data or information to a non-U.S. person.

    Export control restrictions apply not only to international shipments of tangible materials and equipment, but also to the transfer of intangible technical data to some foreign countries or citizens of those countries. The following are examples of exports of technical data that may be restricted under the export rules, depending on the contents of the export and the country, person or organization to which the export is made:

    • Transfers of technical data to someone in another country, including to our fellow employees as well as non-employees.
    • Discussions with any non-U.S. person that discloses technical information
    • Visual inspections by any non-U.S. person of U.S.-origin equipment and facilities
    • You should be aware that the release of certain technical data and information to a non-U.S. person may be a “deemed export” to the country where the non-U.S. person is a citizen, even if the release occurs inside the United States
    • The laws of the United States and other countries also contain prohibitions against dealing with specifically identified countries, persons or organizations, including those countries where the United States enforces economic and trade sanctions (e.g. Cuba, Iran, North Korea, Sudan and Syria, among others)

    We are also subject to anti-boycott provisions of U.S. law that prohibit or penalize U.S. companies from participating in or cooperating with foreign boycotts that the United States does not sanction.  These laws, which are primarily targeted at the Arab League boycott of Israel, also impose certain reporting requirements.

    International trade compliance also involves complying with documented procedures and work-instructions to help ensure that accurate customs declarations are made to the relevant customs authorities in all jurisdictions. Customs authorities require that accurate information be disclosed with respect to inbound shipments, so that applicable duties, taxes and fees may be levied, and so that compliance with various border-enforced laws and regulations can be ensured.

    The laws regulating imports/exports and international trade are complex, frequently changing and in certain regions may conflict. Employees must consult with the designated individual within their organization or the Legal department as early as possible about local laws on exporting/importing products, information and technology.

    MAKE SURE YOU

    • Know the business partners with whom you are dealing as well as the final destination of our products
    • Obtain all necessary licenses before the export or deemed export of products, services, or technology
    • Report complete and accurate information on every imported product, such as its proper classification, places of manufacture, and full cost
    • 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 Legal, Corporate Compliance, Finances, and Global Trading Management

    WATCH OUT FOR

    • Any request to join in, support, or furnish information concerning a non-U.S. boycott and immediately report any such requests to the Legal department
  • To learn more

    • Global Trade Compliance Control Policy
    • Global Third-Party Due Diligence Screening SOP
    • Discuss any questions or concerns about international business with your manager, Global Trade Management, Compliance, Legal, Human Resources partners or contact the Helpline

    For all policies refer to the iNet

  • Political Involvement

    You have the right to voluntarily participate in the political process including making personal political contributions and advocating as a private citizen.  However, you must always make it clear that your personal views and actions are not those of the Company.  Also, never use Company funds, assets, services or facilities to support any political candidate or party or to engage in any lobbying activity unless specifically authorized by the Corporate Affairs Department.

    Lobbying on behalf of the company is a highly regulated corporate activity conducted by the Corporate Affairs department. Employees who wish to engage in lobbying activities for valid business reasons on behalf of the corporation must coordinate those activities with corporate Affairs.

    MAKE SURE YOU

    • Receive all needed approvals before using Company resources to support political activities
    • Make sure your personal political views and activities are not viewed as those of the Company

    WATCH OUT FOR

    • Improper Influence
      Avoid even the appearance that your contributions or participation in political activities may be intended to gain improper influence
    • Conflicts Of Interest
      Holding or campaigning for political office must not create even the appearance of a conflict of interest with your duties to the Company

    Being ethical means doing the right thing even when no one is watching.

  • To learn more

    • Global Conflict of Interest and Outside Activities Policy
    • Global Political Contributions Policy
    • Discuss any questions or concerns about political contributions or political activities, with your manager, the Corporate Affairs department, Compliance, Legal, or contact the Helpline

    For all policies refer to the iNet

  • Questions & Answers

    Question:

    I will be attending a fundraiser for a local political candidate. Is it OK to list my position at Biogen as long as I don’t use any Company funds or resources?

    Answer:

    You will need to understand and comply with the laws and regulations that apply to your contribution.  For example, U.S. Federal law requires candidates for federal office to collect information from donors contributing $200 or more including their employer’s information (other countries have similar laws). You must provide this legally required information, but under no circumstances can you indicate that your participation or support in political activities is representative of Biogen views. 

    Question:

    I would like to invite an elected official, such as a congresswoman or a state legislator, to speak at an upcoming Company event. Would that be a problem?

    Answer:

    You must coordinate with the Corporate Affairs department before inviting a government officer to attend a Company event.