We never... compromise our integrity
Integrity is the foundation on which we build our business. We demonstrate integrity and earn the trust and respect of our constituencies through the actions of every employee. We do what we say and we say what we mean.
Conflicts of Interest
A conflict of interest occurs when you have a competing interest that may interfere with your ability to make an objective decision. Each of us is expected to use good judgment and avoid situations that can lead to even the appearance of a conflict.
Conflicts of interest may be actual or just a matter of perception. Since these situations are not always clear-cut, you need to fully disclose them to your manager, Human Resources, Legal or Corporate Compliance so that we can properly manage them.
MAKE SURE YOU
- Disclose the full details of any situation that could be perceived as a conflict of interest
- Proactively address situations that may put your interests or those of your family in conflict with Biogen
- Avoid using your position or Company resources for personal advantage
WATCH OUT FOR
Situations such as the following are common examples of conflicts of interest:
- Self-Dealing & Corporate Opportunities
If you learn about a business opportunity because of your job, do not take that opportunity for yourself unless you get appropriate Biogen approval. Also, giving business to a firm that will benefit an employee or family member is another example of a conflict of interest
- Outside Employment
Outside employment or business engagement should be discussed with your manager. Also, any approved personal business that you or your family operates should not compete with Biogen
- Financial Dealings and Investments
Ownership by you or your family of an interest in a company that is a competitor, vendor, supplier, customer, or partner of the Company could be a conflict
- Participating in Other Organizations
You shouldn’t accept a seat on the board of directors or advisory board of, or volunteer with, any of our competitors, suppliers, customers or partners without appropriate approval
- Personal Relationships
Romantic or personal relationships may create perceived conflicts of interest and should be discussed with your manager, and Human Resources. You should disclose any personal relationship with colleagues or external stakeholders that may be perceived as involving a potential conflict of interest, using the link provided in the Global Conflicts of Interest and Outside Activities Policy. If you are uncertain if the relationship qualifies as a conflict of interest you should discuss with your Compliance officer
- Acceptance of Gifts
Acceptance by you of gifts or other benefits greater than nominal value could be a conflict of interest
Questions & Answers
Jon works in a Biogen manufacturing facility. He is having trouble covering his personal expenses and has been thinking of getting a second job. He found one that seems perfect at MegaPharma, a Biogen supplier, and applied for it. MegaPharma called to offer him the job. What should Jon do before starting the job?
Jon should disclose the new job opportunity to his manager to determine whether there is a conflict and how best to handle it. The important thing is for him to disclose the potential conflict to Biogen, so the company may help him work through the issues, and manage any potential conflicts.
My wife manages a training consulting firm. Can she submit a proposal to become a Biogen vendor?
You should report this relationship to your manager, or Human Resources, refer the request to Procurement, and refrain from participating in Biogen’s discussions or decision on this matter. The most important action with any potential conflict of interest is to disclose it so it can be properly managed.
One of my direct reports is dating an employee is a different department. Is this allowed?
There could be a potential conflict depending on their roles and whether one has influence or control over the other’s employment (compensation, evaluations, etc.). You should report any intimate personal relationships at work. Potential conflicts of interest can be reported using the link in the Global Conflict of Interest and Outside Activities Policy.
Gifts and Hospitality
In the right circumstances, a modest gift may be a thoughtful “thank you,” or a meal may be an appropriate setting for a business discussion. However, if not handled carefully, the exchange of gifts and hospitality can create the appearance of a conflict of interest, especially if it happens frequently or if the value is large. When it comes to gifts and hospitality, Biogen’s position is straightforward: we do not accept or provide gifts or hospitality or any other item of value if the intent is to influence a business decision. Gifts of cash or cash equivalents are never allowed. And, when it comes to healthcare professionals, special rules apply. Those rules should be followed regardless of intent.
MAKE SURE YOU
- Use sound judgment, only provide and accept gifts and hospitality that are permissible by law and policy and that are reasonable complements to business relationships
- Understand and comply with the policies of the recipient’s organization before offering or providing gifts, hospitality or any other item of value
- Do not accept a gift, hospitality, or entertainment from a business connection that is not modest and reasonable and that may give the appearance of improper influence
WATCH OUT FOR
- Situations that could embarrass you, Biogen or the recipient
- Relationships and transactions that could create a perception of divided loyalties or improper influence
Questions & Answers
While traveling, I received a gift from a business partner that I believe was excessive. What should I do?
You need to let your manager know or report it to the Corporate Compliance department as soon as possible. We may need to return the gift with a letter explaining our policy. If a gift is perishable or impractical to return, another option may be to distribute it to employees or donate it to charity, with a letter of explanation to the donor.
During contract negotiations, a potential new supplier mentioned that they had a complimentary registration to a local business seminar and offered it to me. I had been thinking of attending the seminar anyway as it is relevant to my work. There’s no personal gain to me, it would be good for, and it would be a shame to waste the registration, so I planned on saying ‘yes.’ Now I wonder if that’s the right decision.
You should decline the offer. If you are involved in contract negotiations, you must never accept any gifts while the negotiation process is ongoing. Accepting gifts during negotiations can give the appearance of a ‘quid pro quo’ and is always inappropriate.
Special Rules for Gifts and Hospitality to Government Representatives
Interactions with government employees involve additional considerations beyond the kind of common sense, sound judgment principles described above. We are committed to complying with the many legal, regulatory and contractual requirements that specifically apply to government-related work around the world. To that end, you must always make sure you know whether you are dealing with a government official or government-related entity and follow rules applicable to them.
The Public Policy & Government Affairs, Legal and Compliance departments are available to help you with questions about who may be a government representative.
Questions & Answers
Mary Jones, a Biogen Medical Science Liaison, often works with Dr. Gary Smith, whose employer is a government public hospital. The holidays are approaching and Mary is thinking about sending Dr. Smith a gift basket filled with three bottles of wine and a wide variety of chocolates.
Mary should refrain from sending the gift because it is not educational in nature, is considerable in value, and gifts to government employees/ representatives are not permitted without prior approval of the Biogen Public Policy & Government Affairs department and Legal. In addition, if Dr. Smith is a healthcare professional, this gift – which is not educational – would not be permissible in some jurisdictions.
Joe Mitchell works in Biogen’s IT group. A number of projects he is involved with require him to work with Sally Reagan, a contractor from IBM regularly. Sally and Joe have become good friends and Joe would like to give her box seat tickets to a baseball game as appreciation for her on-going efforts. What should Joe do?
Joe should refrain from giving the tickets to Sally because they are not considered nominal in value.