We are all responsible for Biogen
Individually, and as members of the Biogen team, each of us is responsible for acting with integrity every day. Each of us must accept this commitment for ours is a shared responsibility.
Doing the Right Thing in Today's Business Environment
At Biogen, we understand and accept our responsibilities to respect and care for our patients, fellow employees , to always act in accordance with our Core Values and to comply with all applicable laws and regulations. Each of us must accept this commitment for ours is a shared responsibility.
Doing the right thing in today’s business environment is not always easy. Healthcare laws and regulations change, and situations involving ethics can be complicated. While our commitment and our responsibilities are clear, sometimes it is difficult to know what to do in certain situations. That is why we periodically revise our Code of Business Conduct, and provide you with resources to help you understand our standards and expectations, to help you exercise sound judgment and make good choices for the Company, for our patients and customers, and for yourself.
Who's Covered by This Code?
This Code provides the ethical guidelines and expectations for conducting business on behalf of the Company.
This Code applies to all employees, officers and directors. Certain business partners, such as joint ventures, agents, consultants, distributors, suppliers, vendors, independent contractors, and temporary employees are also expected to live up to the principles of the Code. Managers who supervise our external business partners are responsible for ensuring that they understand our standards.
We all want to do the right thing, and the guidance in this Code can help us achieve that important goal.
Ethics Every Day — Our Responsibilities
- Always act in a professional, honest, and ethical manner when acting on behalf of the Company
- Be familiar with the information contained in this Code as well as Company policies
- Complete all required training in a timely manner and keep up-to-date on current standards and expectations
- Promptly report concerns about possible violations of laws, regulations, this Code and policies to your supervisor or to any of the resources listed in this Code
- Remember: no reason, including the desire to meet business goals, is an excuse for violating laws, regulations, the Code or policies
Questions & Answers
I was recently called into my manager’s office for violating policies laid out in the Code. I was unaware that I had violated any policies and, in turn, do not think I should be held responsible. Can I be held accountable even though I was unaware of the requirement?
Yes. As an employee, you are expected to know and follow our Written Standards, including the Code, and to know when to ask for clarification of something you don’t understand. Failure to follow our Written Standards may lead to disciplinary action that could include loss of employment.
MANAGERS HAVE ADDITIONAL RESPONSIBILITIES
If you are in a leadership position you are expected to meet the following additional responsibilities:
- Lead by example. Managers are expected to exemplify the highest standards of ethical business conduct
- Be a proactive resource for others
- Communicate to employees and business partners about how the Code and policies apply to their daily work
- Look for opportunities to discuss and address ethics and ethically challenging situations with others
- Create an environment where compliance is recognized and valued and where everyone feels comfortable asking questions
- If you supervise external business partners ensure that they understand their ethics and compliance obligations
Questions & Answers
I’m a supervisor and I’m not clear what my obligations are. What if someone comes to me with an accusation involving a senior leader?
No matter who the allegation involves, you must report it without exception. The Company provides several avenues for reporting concerns. If for any reason you are uncomfortable making a report to a particular person, you may contact the Helpline or talk to any of the other resources listed in the Code or another member of management.
I’m a manager. If I observe misconduct in an area not under my supervision, am I still required to report the issue?
Yes. Although you are chiefly responsible for employees, contractors and third parties under your supervision, but all Company employees are required to report any misconduct of which they become aware. As a leader you are especially obliged to take action. The best approach is to talk first with the supervisor who oversees the area where the problem is occurring. If this doesn’t work, or isn’t feasible, you should use other resources listed in the Code such as contacting your HR Partner or the Compliance Helpline.
Speak up if you have any concerns. Biogen strictly prohibits retaliation. This is a cornerstone of the Compliance Program. We do not tolerate any form of retaliation, whether by a manager or co-worker, against an individual because he or she made a good faith report of a legal or ethics concern. This non-retaliation policy also extends to anyone who assists with or cooperates in an investigation or reports a legal or ethics concern.
Questions & Answers
I discussed a concern with my manager, and she said she would look into it but nothing has happened. Several weeks have passed, and the situation that caused my concern is still occurring. I am afraid to ask my manager again. What should I do?
You should continue to raise your concern until it has been addressed. In this situation, you should consider contacting your manager’s manager, another manager, the Compliance Helpline, or one of the other resources listed in the Code. While it is possible that your manager looked into the situation and determined that there was not a problem, it would be helpful for you to know, one way or the other. Contacting a different resource may help clarify the situation.
Compliance with Laws, Regulations, and Standards
We live and work in a global environment and face a number of laws and regulations governing our industry’s operations. These laws and regulations have a direct impact on our daily work. They also govern our interactions with our many business partners and associates such as researchers, patients, healthcare professionals and governments.
We understand that these laws and regulations are there to help protect the patients, customers, and investors we serve. For that simple reason, we are committed to upholding the letter and spirit of these laws and regulations wherever we do business, succinctly summarized as follows:
- Everywhere we operate; we must be aware of and comply with laws and regulations that govern our business activities
- Since we operate in many different countries and jurisdictions, there may seem to be a conflict between applicable laws. When you encounter such a conflict, consult with the Legal Department
We comply with applicable global standards such as:
- The International Labour Office Tripartite Declaration of Principles Concerning Multinational Enterprises and Social Policy
- The Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises
- The Declaration of Helsinki
- Good Laboratory Practices (GLPs)
- Good Clinical Practices (GCPs)
- Good Manufacturing Practices (GMPs)
- The Biotechnology Industry Organization Statement on Protecting Research and Research Participants
- The Pharmaceutical Research and Manufacturers of America’s (PhRMA) Code on Interactions with Healthcare Professionals, Guiding Principles on Direct to Consumer Advertising, and Conduct of Clinical Trials
- The European Federation of Pharmaceutical Industries and Association (EFPIA)
- The International Federation of Pharmaceutical Manufacturers and Associations (IFPMA)
- Rules and regulations issued by the U.S. Securities and Exchange Commission
- Biogen Climate Change Position Statement 2016
- Biogen Human Rights Position Statement 2016
Accountability and Discipline
Violating relevant laws, regulations, or the Code, or encouraging others to do so, exposes the Company to liability and puts both your own and the Company’s reputation at risk. The Company will take appropriate disciplinary action against any employee or business partner whose actions are found to violate these policies or any other policies of Biogen.
Where laws have been violated, we will cooperate fully with the appropriate authorities.