OUR ETHICAL STANDARDS
Ethics and Compliance, Every Day
Every day, we strive to live up to the expectations of patients, physicians, and ourselves, and to earn trust in our communities. We know the importance of this responsibility, and we take it seriously.
Alexion’s Board of Directors and Executive Committee have established an Executive-level Ethics and Compliance program, led by our Chief Compliance Officer, Compliance Committee and Compliance Team. Alexion’s Compliance program is tailored to meet the standards set forth by the Office of Inspector General (OIG) for the U.S. Department of Health and Human Services in its 2003 Compliance Program Guidance for Pharmaceutical Manufacturers.
Alexion’s Compliance & Ethics Hotline
The Alexion Compliance & Ethics Hotline offers employees, business partners, customers, and members of the public the opportunity to ask questions and/or report concerns about any potential misconduct or unethical behavior by Alexion or affiliated parties.
Questions or concerns may be submitted using several methods listed on Alexion.com/EthicsHotline.
Compliance & Ethics Hotline (U.S.): 1-866-516-3413 using the access code 25394
Alexion’s Compliance Program incorporates the seven fundamental elements of an effective compliance program as defined by the OIG:
1. Designated compliance officer and compliance committee
Alexion’s Corporate Compliance Committee is co-chaired by Indrani Franchini, Chief Compliance Officer, and Brian Goff, Chief Commercial & Global Operations Officer. Ms. Franchini reports to Ludwig Hantson, Chief Executive Officer of Alexion, is a member of the Executive Committee and has direct access to the Board of Directors.
2. Implementing written policies and procedures
Alexion’s Code of Ethics and Business Conduct is just one part of our overall program to assure that employees worldwide follow the appropriate standards and comply with all legal requirements that affect the manner in which Alexion operates, including industry guidelines, laws, regulations, and guidance in each country where we do business. Alexion communicates policies and procedures via live training activities and our intranet.
3. Effective training and education
Alexion educates and trains employees and agents at live training sessions, web-facilitated trainings, and via online resources and training programs. The training materials cover the laws and regulations that affect the way Alexion conducts business and is customized (and periodically updated) to meet specific regional requirements.
4. Open lines of communication
As part of our commitment to behaving ethically, Alexion requires employees to report any potential violations of law, regulation or company policies so they can be appropriately addressed. Our goal is that all employees should know where to turn when seeking answers to questions or reporting potential compliance concerns, and should feel comfortable doing so, without fear of retribution. Alexion employees and agents can raise concerns in numerous ways including anonymous reporting online via Alexion’s Helpline Portal at Alexion.EthicsPoint.com or by contacting a member of Compliance, an attorney in the Legal department or an HR Business Partner. Alexion’s non-retaliation policy protects those who raise a compliance concern in good faith from retribution in any form.
5. Internal auditing and monitoring
Internal monitoring and auditing are integral parts of Alexion’s comprehensive Compliance Program. Effective monitoring and auditing can detect and prevent deviations that can potentially prompt compliance concerns. Alexion’s Compliance and Internal Audit functions conduct a variety of monitoring activities in an effort to detect and respond to potential issues of non-compliance. In accordance with the OIG Guidance, our compliance monitoring and auditing program will be modified as necessary in response to new regulatory requirements, changes in business practices, and other considerations.
6. Enforcement of standards through disciplinary guidelines
Our Code of Ethics and Business Conduct and company policies educate employees and agents about Alexion’s commitment to compliance. It is the responsibility of every employee to read, understand and follow these guidance materials. Alexion advises employees that failure to adhere to our ethical and legal standards may have disciplinary consequences, up to and including termination of employment. When the outcome of an investigation shows that discipline is warranted, appropriate action is taken.
7. Prompt response to detected problems through corrective actions
Alexion’s Compliance Program supports prompt response and corrective action for detected problems as appropriate under the circumstances. Regardless of how a potential compliance concern is raised, it will be carefully reviewed, thoroughly and thoughtfully investigated in a timely manner, and appropriately resolved.
Anti-Corruption and Anti-Bribery
Alexion has a zero tolerance policy towards bribery and corruption. We comply with the anti-corruption laws of every country in which we operate, including the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act.
Vendor Code of Conduct
Alexion and its subsidiaries are committed to conducting business in an ethical, legal, and socially responsible manner. We expect our vendors to share this commitment.
Alexion will make public any disclosures necessary to comply with transparency laws or regulations applicable to pharmaceutical manufacturers, including, but not limited to, National Physician Payment Transparency Program (“Open Payments”) in the United States and the Loi Bertrand Act (“Sunshine Act”) in France. These regulations have mandated increased transparency in interactions between healthcare providers and companies manufacturing health care products and/or medical devices. The intention of these requirements is to address potential conflicts of interest in the interactions between these companies and healthcare professionals. To comply with these regulations, Alexion reports certain payments or other transfers of value made in the course of our professional interactions with healthcare professionals and healthcare organizations where applicable.
California Compliance Declaration
Alexion is committed to establishing and maintaining a comprehensive and effective compliance program in accordance with California SB 1765 (California Business & Professions Code 119400, 119402), and the Office of Inspector General, U.S. Department of Health and Human Services, “Compliance Program Guidance for Pharmaceutical Manufacturers.”
I don’t define myself as having a rare disease. It’s part of my life but it’s certainly not who I am.”CHELSEY LIVING WITH NMOSD