Compliance Overview

 

Norgine Business Code

 

The Norgine business code has been adopted by all legal entities within the Norgine Group and is available in seven languages.

The Norgine business code establishes the framework for achieving Norgine’s vision to deliver innovative medicines for the benefit of patients, employees and other stakeholders. As we endeavour to achieve our vision, we must do so through the application of consistently high standards of ethical conduct.

From its inception, the Norgine business code was established based on a broad consultation process across the Norgine Group and a comprehensive consideration of all the activities of the Company.

Inspired by our patients, we harness our entrepreneurial spirit and work together as One Norgine to help people to live better and healthier lives. The Norgine business code will continue to evolve, but it will always embody best practice in the industry and the distinctive characteristics of Norgine’s employees and partners.

 

 

 

ABC, AML, AFTE & FRAUD

 

Wherever Norgine does business, whether directly or indirectly through a third party, Norgine is committed to complying with all applicable anti-bribery and corruption laws, anti-money laundering and counter-terrorist financing laws as well as anti-facilitation of tax evasion laws and laws relating to fraud.
Norgine takes a zero-tolerance approach to bribery and corruption, money-laundering and terrorist financing, the facilitation of tax evasion and fraud. Norgine is committed to acting professionally, fairly, and with integrity in all its business dealings and relationships wherever Norgine operates, and to implementing and enforcing effective systems and controls to counter bribery and corruption, money-laundering and terrorist financing, the facilitation of tax evasion and fraud.

Norgine has adopted formal policies setting out the responsibilities of Norgine Personnel in observing and upholding Norgine’s requirements on preventing bribery and corruption, money-laundering and terrorist financing, the facilitation of tax evasion and fraud. Norgine’s policies provide information and guidance on how to recognise and avoid such activities.

 

 

 

Competition

 

Norgine strives to act with integrity and trustworthiness in all our dealings across external stakeholders, including our competitors.

We support free, robust and open competition, promoting and encouraging fair competition. All Norgine companies abide by the antitrust and competition laws in the areas or countries in which they operate. EU, UK and the US competition requirements are taken into account in our activities, including, notably Articles 101 and 102 of the Treaty on the Functioning of the EU, EU Member States’ equivalent rules, Chapter 1 and Chapter 2 of the UK Competition Act 1998 and Sections 1 and 2 of the U.S. Shearman Act.

Norgine provides Anti-Trust/Competition related training to relevant employees across Norgine and regularly reviews its internal policies.

 

 

Modern Slavery

 

Norgine ensures that it operates ethically, sources responsibly and works to prevent modern slavery and human trafficking throughout our organisation and in our supply chains. We are committed to adhering to international human rights standards such as the UN Declaration of Human Rights and the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work, as well as other applicable national legislation.

We publish our annual statement in accordance with the UK Modern Slavery Act 2015 requirements which you can find here.

We take a zero-tolerance approach to any form of modern slavery or human trafficking in our supply chains and in any other part of our business.

Suppliers and business partners are informed of our expectations and must comply with the Norgine Business Code in all of their dealings with us. We identify and assess potential risk areas and as appropriate seek compliance assurances with third parties with whom we work.

 

 

Sanctions

 

Norgine takes compliance with all applicable economic and financial sanctions, restrictive measures, trade embargoes and export control laws very seriously, and is committed to complying with all such trade controls in all jurisdictions in which Norgine operates while implementing and enforcing effective systems and controls to mitigate the risk of any violations.

Norgine has adopted a formal Trade Controls Policy setting out the general requirements and procedures for Norgine Personnel designed to ensure Norgine’s compliance with any applicable trade controls and providing information and guidance for Norgine Personnel on how to recognise compliance risk and respond appropriately in case of any suspected violations.

 

 

 

Whistleblowing

 

Norgine is committed to conducting its business with honesty, integrity and transparency, and expects all Norgine Personnel to maintain high standards of legal and ethical conduct in accordance with the Norgine Business Code. A culture of openness and accountability is essential in order to prevent wrongdoing, such as illegal or unethical conduct, and to address such situations promptly if they do occur.

Norgine has adopted a formal Whistleblowing Policy. The purpose of this Policy is to encourage Norgine Personnel and third parties to report known or suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected.

Under the Whistleblowing Policy, Norgine has established internal reporting channels which are available for Norgine Personnel and third parties in case they wish to raise a concern. Relevant wrongdoing may include criminal activity, failure to comply with any legal obligation, regulatory requirements or any applicable code of conduct in the pharmaceutical industry, miscarriages of justice, danger to health and safety, damage to the environment, bribery, facilitating tax evasion, financial fraud or mismanagement, breach of our internal policies and procedures and unauthorised disclosure of personal data or confidential information. The Whistleblowing Policy provides further guidance as to how to raise those concerns.

 

Third parties can contact Norgine’s internal reporting channels as follows:

 

Mail:

Norgine Limited
FAO: Compliance Manager / Chief Legal Officer / Chief Financial Officer / Senior Director Due Diligence
Norgine House, Widewater Place, Moorhall Road
Harefield Middlesex UB9 6NS
United Kingdom

 

Email:

 

Online:

 

Norgine takes a zero-tolerance approach to wrongdoing, including any detrimental treatment of a whistleblower as a result of raising a genuine concern in respect of suspected or actual wrongdoing.

 

 

 

Donations and grants

 

Norgine recognises its obligation to make Donations and Grants responsibly and to act with integrity and in compliance with Legal Requirements, its contractual obligations and internal processes.  Transparency and compliance are the cornerstone of the Donation and Grant review process.