The UCB Code of Conduct encompass, amongst others, core principles and behaviors aiming at mitigating the risks related to bribery and corruption as well as human rights infringement. Considering the nature of our business, UCB identified our engagement of the healthcare stakeholders as the primary ABAC risk area. ABAC risks are reported in Risk Management section of this report.
A dedicated ABAC training has been developed and assigned to those employees most exposed. This generated a global completion rate of 97%, including 97% for the EU, 99% for the U.S., and 96% for international markets.
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. 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.
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 concerns. Employees are encouraged to report suspected non-compliance or misconduct to their manager or their primary contacts in Legal / Ethics & Compliance / Talent departments. Where this is not an option, UCB provides a confidential, toll-free reporting line (known as the Integrity Line™), which is available 24 hours a day, 365 days a year, and in 58 languages for online reporting and over 200 language options for telephone reports. Information received via this forum is treated as sensitive and investigated, on a priority basis, for appropriate corrective action. UCB also has a non-retaliation policy to protect individuals raising concerns.
In 2020, only one case related to ABAC was identified and investigated. The allegation was substantiated and investigations on this case led to disciplinary action.
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 audits 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.