We respect the privacy and safeguard the security of the personal information we collect. Protecting the information we hold is fundamental to our commitment to patients, healthcare professionals, business partners, employees and the communities we serve.

Treating Highly Sensitive Information with Care

One of our most valuable assets is information. Each of us must be vigilant and protect Biogen’s highly sensitive or confidential information, as well as highly sensitive and confidential information disclosed to us. Your obligation to preserve Biogen’s highly sensitive and confidential information continues even after your employment with our Company ends.

MAKE SURE YOU

  • Use and disclose highly sensitive and confidential information only for legitimate business purposes
  • If sharing externally, use appropriate contract templates or confer with legal to determine what safeguards should be in place
  • Properly label highly sensitive and confidential information to indicate how it should be handled, distributed and destroyed in accordance with applicable policies
  • Only store or communicate Company information using Biogen’s information systems or approved storage devices/locations
  • If required to transfer, highly sensitive or confidential information ensure that the appropriate security controls are used, including encryption
  • Safeguard company assets and ensure that the appropriate authorization is obtained for the use or disposition of company assets

WATCH OUT FOR

  • Discussions about highly sensitive or confidential information when others might be able to overhear what is being said – for example on planes, elevators and when using mobile phones
  • Transmission of highly sensitive information to unattended fax machines or printers
  • Leaving your work area unattended with confidential information displayed
  • To learn more

    • Global Information Security Policy
    • Global Data Risk Classification Policy
    • Global Records and Information Management Policy
    • Discuss any questions or concerns about highly sensitive or confidential information with your manager, Information Governance, Legal, or Human Resources partners

    For all policies refer to the iNet

  • Insider Trading

    We will not use Biogen information or information from our business partners for personal benefit. Our Insider Trading Policy prohibits all of our directors, officers, employees, and temporary staff worldwide, as well as their immediate family members, from trading securities, or disclosing or passing along information to others who then trade (i.e., “tipping”), on the basis of material nonpublic information. You may only purchase or sell a company’s securities if you are not in possession of material non-public information about the company. Additionally, certain individuals are subject to additional trading restrictions, which limit those individuals to trading in the Company’s securities only during certain open trading windows or under a 10b5(1) trading plan. Material information is information that a reasonable investor would consider important in deciding whether to buy sell or hold a security. Some examples of information that may be considered material include:

    • A pending or proposed acquisition, sale or other significant transaction
    • Results of late-stage clinical trials
    • A significant product development or important information about a product, such as serious product safety issues
    • Receipt of regulatory approval or failure to obtain regulatory approval for products
    • Earnings or financial performance
    • Significant litigation or patent-related events

    Information is considered non-public if it has not been previously disclosed to the public through press releases or SEC filings and is otherwise not available to the general public. Information is generally considered “public” after it has been publicly available for at least one business day after disclosure. Violations of the insider trading laws are severe, and include civil and criminal fines and penalties. It is your responsibility to ensure that you do not violate the insider trading laws or our Insider Trading Policy.

    MAKE SURE YOU

    • Do not buy or sell securities of Biogen or any other company when you have material non-public information about Biogen or that other company
    • Do not communicate material non-public information to any other person
    • Do not engage in short sales, puts, calls, hedging transactions, margin accounts, pledges or other derivative transactions related to Biogen securities
    • Do not trade during “blackout periods” or without a 10b5(1) trading plan if you have been notified you are subject to such trading restrictions

    WATCH OUT FOR

    • Requests by friends or family for information about Biogen, our customers or any other company with which we do business. Even casual conversations could be viewed as illegal “tipping” of inside information
  • To learn more

    • Global Insider Trading Policy

    For all policies refer to the iNet

  • Questions & Answers

    Question:

    I am aware of a significant new development in our business that I think is going to significantly increase the value of the Company’s stock. I know that I am prohibited from buying stock, but I can recommend that my friend invest in our Company, right?

    Answer:

    No, you must not do that. You are correct that you may not trade in Company stock with this information, as it is “material non-public information.” Trading in Company stock while in possession of this type of information is insider trading and against the law. However, you are also forbidden by Company policy and the law from making any recommendations to others to buy or sell Company stock based on this type of information, even if you do not share that information when making the recommendation. Doing so would be considered “tipping” and could subject both you and your friend to civil and criminal penalties.

    Question:

    I have discovered through my work with the Company that one of our vendors is planning a partnership with a small publicly traded company. It seems like a great time to invest in the smaller firm, and they’re not one of our vendors. May I do so?

    Answer:

    No. You are in possession of “material non-public information” and must not trade on it. If and when the information about the partnership becomes public, you may make the purchase, but not before.

  • Protecting Company Assets

    We are each personally responsible for protecting Company assets and using them with care. Company assets include funds, facilities, equipment, information systems, intellectual property and confidential information. Personal use of Company assets is discouraged.

    All information that is sent or received through our computer or phone systems is part of official Company records, and we can be legally required to show those records. Therefore, make sure that business information you process is accurate, appropriate, ethical, and legal.

    MAKE SURE YOU

    • Use Biogen assets only for legitimate business purposes
    • Do not use Biogen equipment or information systems to create, store or send content that others might find offensive
    • Do not share passwords
    • Only use properly licensed software. The use of “pirated” software is strictly prohibited
    • Keep personal use of Company assets to a minimum and ensure that such usage has no adverse effect on productivity and the work environment

    WATCH OUT FOR

    • Excessive or inappropriate use of Biogen resources for personal purposes
    • Sharing passwords
  • To learn more

    • Global Contract Review Policy
    • Global Mobile Telecommunications Policy (U.S. and International)
    • Global Purchasing Policy
    • Global Approval Policy
    • Global Travel and Expense Policy
    • Global Email and Electronic Communication System Retention Policy
    • Global Information Security Policy
    • Global Password Policy
    • Global Conflicts of Interest and Outside Activity Policy
    • Discuss any questions or concerns about protecting Biogen assets with your manager, Global IT Security, local Compliance, Legal, Human Resources partners, or the Helpline

    For all policies refer to the iNet

  • Intellectual Property

    Biogen’s intellectual property (IP) is an important asset that must be protected. Some examples of our IP are:

    • Trade secrets and discoveries
    • Methods, know-how and techniques
    • Innovations and designs
    • Systems, software and technology
    • Patents, trademarks and copyrights

    MAKE SURE YOU

    • Promptly disclose to company management any inventions or other IP that you create while you are employed by Biogen
    • Properly label confidential information to indicate how it should be handled, distributed and destroyed
    • Protect IP by sharing it only with authorized parties
  • To learn more

    • Discuss any questions or concerns about IP-related communications with your manager or Legal
  • Communications with the Public

    To achieve a consistent voice and message when making disclosures or providing information to the public, only authorized persons may speak on behalf of the Company. Please note that our colleagues in Corporate Affairs, Investor Relations and the Executive Management team are the only company employees authorized to speak to media and the financial community. We expect all employees to be careful when using any social media. If you participate in online forums, blogs or bulletin boards, do not discuss the Company or its business and never give the impression that you are speaking on behalf of Biogen. Before you hit the ‘send’ button, think carefully. Don’t send emails or post confidential information or material that could damage the Company’s reputation.

    MAKE SURE YOU

    • Never speak publicly on issues involving the Company without prior authorization from Corporate Affairs or Investor Relations. All content must then be reviewed and approved and the speaker must have the appropriate training
    • Refer any inquiries about our activities, sales or financial results, or strategic plans to Corporate Affairs or Investor Relations
    • Get approval from Corporate Affairs before distributing any communication intended for a broad employee audience

    WATCH OUT FOR

    • Any suggestion in your personal communications that you speak for the Company
    • Using your Company title or affiliation outside work – such as in non-Company sponsored charitable or community work – without making clear that you are not representing the Company
  • To learn more

    • Global Social Media Policy
    • Discuss any questions or concerns about public communications with your manager or Corporate Affairs

    For all policies refer to the iNet