Anti-bribery and anti-corruption
UCB’s Code of Conduct, which is part of mandatory training for all UCB employees, includes anti-bribery and anti-corruption (ABAC) standards. 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 employees, 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 employees interacting or engaging with external stakeholders;
- systematic process controls of financial transactions to healthcare stakeholders, including review and approval of activities and associated transfer of value by UCB management and/or independent functions, such as, Ethics & Compliance;
- regular monitoring on adherence and effectiveness of those controls are taking place, including monitoring of transfer of values and audit of these by Finance, Ethics & 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; and
- any third party, acting on behalf of UCB, and engaging with those stakeholders is expected to and is contractually obliged to respect the highest standards, including the ABAC standards, and such third parties should have internal standards and controls in place or agree to adhere to those defined by UCB, among others.
To date, no corruption or bribery by UCB or selected third parties acting on behalf of UCB have been identified. Reported allegations of individual misconduct have been systematically investigated and disciplinary actions were taken. In order to measure our success, the relevant KPI’s are listed in the GRI G4 Sustainability Indicators, category ‘Social’.