Asking questions and reporting possible violations
Asking questions and reporting possible violations are crucial responsibilities for all of us at Biogen and have a direct impact on protecting our Company and ensuring we all act responsibly.
The tools and resources below are here to help if you are unsure how to act in a particular situation, have a concern or need to report possible misconduct.
Where to Go for Help
If you see or suspect any illegal or unethical behavior, or you have a question about what to do in a certain situation, you have a responsibility to speak up. Remember, an issue cannot be addressed unless it is brought to someone's attention.
You can ask questions and report possible ethical or legal violations by using the Helpline. But most importantly, you are encouraged to speak with the person with whom you feel most comfortable — that may be:
- Your supervisor or manager
- Another supervisor or any member of management
- Corporate Compliance
- Human Resources
We Will Not Tolerate Retaliation
Regardless of the type of misconduct reported, we will not tolerate retaliation against anyone who makes a good faith report of an alleged violation of laws, regulations, the Code or policies. We take claims of retaliation seriously. All such claims will be thoroughly investigated and resolved. If you believe you have been retaliated against because you reported misconduct, you should notify the Corporate Compliance department or the Helpline. Anyone found to have retaliated will be disciplined up to and including termination.
Questions & Answers
I suspect there may be some unethical behavior going on in my business unit involving my supervisor. I know I should report my suspicions, and I’m thinking about using the Helpline, but I’m concerned about retaliation.
You are required to report misconduct and using the Helpline is a good option for you. We will investigate your suspicions and will follow up with you as needed to get additional information. We will protect the information you provide to us. After you make the report, if you believe you are experiencing any retaliation, you should report it.
Ethical Decision-Making: A Headline Test
Making the right decision is not always easy. There will be times when you will be under pressure or unsure of what to do. Always remember when you have a tough choice to make, you are not alone. Your colleagues and management are available to help, and you have other resources to turn to including the Code, our policies, your supervisor, and the resources cited throughout this Code.
When faced with a tough decision it may help to ask these questions:
- Is my action ethical, legal and consistent with Our Credo and Core Values?
- Is it consistent with the Code and policies?
- Is it based on a thorough understanding of the possible consequences?
- Will I be able to look myself in the mirror and be proud of the decision?
- Would I still be comfortable with the decision if it appeared in the newspaper?
You might also use the following Headline Test diagram to think through the soundness and impact of your business decisions and actions on behalf of the Company.
Before acting on behalf of the Company, ask yourself: How it would look if my action were to be a headline on the front page of the newspaper, captured on the internet or on a leading pharma blog?
Questions & Answers
My Department sets various goals that we are asked to achieve. Sometimes I feel pressured to violate the Code to achieve these goals. Is this acceptable?
No. While successful businesses set high goals and employees strive to achieve them, you should never violate the Code or our policies to achieve goals.