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Gobbledygook – The Anti-Bribery Report Of Novartis


Novartis belongs to the long and growing list of repeat FCPA offenders.

As highlighted here, in 2020 the company resolved a $347 million FCPA enforcement action concerning conduct in Greece, Vietnam, and South Korea and as highlighted here in 2016 the company resolved a $25 million FCPA enforcement action concerning conduct in China.

Against this backdrop, it was interesting to review the company’s “Anti-Bribery Report” recently released by the company.

The introduction of the report states:

“We recognize the increased expectations of our stakeholders, and society overall, to be transparent in our efforts to combat bribery and corruption in our operations by sharing relevant information about our Ethics, Risk, and Compliance program. Transparency plays a key role in building trust and is also an important part of our Environment, Social and Governance (ESG) agenda and disclosure.

We have therefore participated in a collective action, together with other pharmaceutical companies, to develop relevant indicators that aim to enhance reporting on companies’ anti-corruption efforts to external stakeholders. The outcome of this action initiated by the Norges Bank Investment Management and facilitated by the Basel Institute on Governance resulted in a guidance note, which contains 17 indicators covering five broad themes, namely, Culture, Risk Management, Third Parties, Compliance Function, and Oversight.

The guidance note, which also contains supporting descriptors, can be found here.

How we address these indicators for Anti-Bribery Compliance across the different areas can be found in this report.”

My own two cents is that the report is so full of buzzwords and cliches and a form of corporate virtue signaling that it is close to being substantively meaningless.

Example include:

“Ethics and integrity play an integral part in leadership decisions and are embedded at the individual level across the organization. They are also an integral part of our hiring and selection process. In addition, we have developed and implemented several programs and tools to support leaders dealing with ethical dilemmas.

Unbossed Leadership Experience (ULE) ULE is a targeted transformational journey to support our leaders to fully embed the cultural aspiration of Inspired, Curious, Unbossed, and Integrity in their leadership style.”

“Novartis is committed to doing what is right. On September 1, 2020, we launched our new Code of Ethics globally. Developed with modern techniques to produce an innovative product, the new Code has three anchors: (i) behavioral, data, and decision science; (ii) co-creation; and (iii) collaboration.

“The “Why Good People” Program is an awareness program supporting our organization’s journey toward a value-based culture. It is offered as a 3.5 hour session, both in classroom and virtual settings. Groups are typically between 10-20 associates. It is aimed at helping our organization move from “unconscious unethical” to “unconscious ethical”. This means fostering a culture where mistakes are acknowledged, discussed, and learned from, and where there is a clear sense of “walking the talk” from the top.”

“Our Values and Behaviors (which includes Integrity) are an integral part of all talent and leadership development programs at Novartis. At Novartis, we take an ‘end-to-end’ approach to associate development from recruiting and onboarding, through professional and leadership development.”

But if “benchmarking” (whatever that means) is your thing, and if you have FOMO (fear of missing out) you may want to check out the report.


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