1.2 Anti-Bribery and Anti-Corruption (ABAC)

1.2 Anti-Bribery and Anti-Corruption (ABAC)

Considering the nature of our business, UCB identified our engagement of the healthcare stakeholders as the primary ABAC risk area.

Beyond the Code of Conduct, principles, processes and controls are in place, embedded in UCB Business Compliance Policy and procedures related to healthcare stakeholders’ engagement. Beside the mandatory training on UCB Code of Conduct, training on our Business Compliance principles and procedures related to Healthcare Stakeholders’ engagement are part of the onboarding of new employees aimed at interacting and engaging with these healthcare stakeholders.

A dedicated ABAC training has been developed and assigned to those employees most exposed. In 2019, a total of 1 166 UCB employees have been following the ABAC training (completion rate of 97%).1To learn more visit People data section.

UCB continues to foster its compliance program, based on structured risk assessment. Elements of UCB compliance program include automation of controls and detection systems, continuous training and communications, monitoring and audit as well as investigation and resolution of suspected misconducts.

The ethics and compliance department performs a regular risk assessment of our affiliate operations, including specific assessments of risks related to ABAC. Minimization strategies are defined and implemented following this exercise.

Further, all engagements of healthcare stakeholders including transfer of value are subject to a review and approval process by separate functions including the review of compliance elements of the engagement.

Our ethics and compliance strategy involves ensuring an open environment where our employees have the space and confidence to report a suspected compliance breach or other concern. Employees are encouraged to report suspected non-compliance or misconduct to their manager or their primary contacts in Legal / Ethics and Compliance / HR departments. Where this is not an option, UCB provides a confidential, toll-free reporting line (known as the Integrity Line™), which is available to all employees in 26 languages and is managed 24 hours a day, every day of the year. Information received via this forum is treated as sensitive and investigated, on a priority basis, for appropriate corrective action.

In 2019, 52 cases have been investigated following reported allegations. 11 related to ABAC, two related to Human Rights, and 39 related to compliance with pharmaceutical specific regulations. two allegations were found substantiated in the field of ABAC (two ongoing investigations); zero allegation had been substantiated in the field of Human Rights (one ongoing investigation) and 15 allegations had been substantiated related to pharmaceutical regulations (three ongoing investigations). Investigations on these cases led to 10 disciplinary actions including dismissal of involved employees.

As a critical component of UCB’s overall internal control environment and structure, UCB Global Internal Audit provides independent, objective assurance activities designed to evaluate and improve UCB’s internal control and operations, including to ensure compliance with applicable laws, rules, regulations and our Code of Conduct. The Internal Audit department periodically audit UCB’s global operations for potential risks related to these areas in accordance with an established rotational schedule or on an issue basis where appropriate. They continuously monitor, enforce and follow up on any compliance-related findings.

1 To learn more visit People data section.