1.4 Anti-bribery and anti-corruption
UCB’s Code of Conduct, which is part of mandatory training for all UCB people, includes Anti-bribery and Anti-corruption (ABAC) standards – considered a very relevant Material Aspect. In addition, UCB includes these standards in its Business Compliance policy and procedures related to healthcare stakeholders’ engagement.
Bribery and corruption risks in the healthcare sector predominantly exists in bribery in medical service delivery, corruption in the procurement value chain, improper marketing relations, misuse of level positions, undue reimbursement claims, and fraud and embezzlement of medicines. These risks of bribery or corruption may arise from UCB people, as well as, from third parties acting on behalf of UCB.
There are various processes in place to support the ABAC policies, such as:
- speciﬁc ABAC trainings for those people interacting or engaging with external stakeholders;
- systematic process controls of ﬁnancial transactions with healthcare stakeholders, including review and approval of activities and associated transfer of value by UCB management and/or independent functions, such as, Ethics and Compliance;
- regular monitoring on adherence and effectiveness of controls are taking place, including monitoring of transfer of values by Finance, Ethics and Compliance and Global Internal Audit departments;
- Integrity Due Diligence is being deployed across UCB to identify prior history of ABAC standards violation by our potential partners engaging with healthcare stakeholders on UCB’s behalf;
- effective monitoring of transfer of value by a systematic review of ﬁnancial transactions in the form of fee for services, grants, donations or sponsorship of those stakeholders, as well as, non-ﬁnancial transactions such as organization of business travels and scientiﬁc/medical events;
- any third-party, acting on behalf of UCB, and engaging with stakeholders is expected to and is contractually obliged to act according to the highest standards, including the ABAC standards. The third parties should have internal standards and controls in place or agree to adhere to those deﬁned by UCB, among others.
UCB’s Global Internal Audit department periodically audits UCB’s operations for potential risks related to the areas described above in accordance with an established rotational schedule. In 2018, three corruption cases involving UCB people or third parties acting on behalf of UCB were identified. Reported allegations of individual misconduct was systematically investigated and disciplinary actions were taken.
Furthermore, UCB complies with public disclosure obligations of ﬁnancial transactions with healthcare organizations, healthcare professionals and patient organizations. Speciﬁc obligations are in place in Europe, Turkey, Russia, U.S., Japan, New Zealand and Australia, and UCB strives to comply with transparency regulations and codes where available.