Policies and guidelines

In order to prevent insiders from benefiting from confidential information, the Board of Directors issued guidelines on how to deter both corporate insiders and external consultants from making use of confidential information. The Board of Directors has established so-called blocking periods to prevent insiders from trading during sensitive periods. The Board of Directors approved and implemented an amended Insider Directive with effect 25 September 2008, which is in compliance with the EU directive on Market Abuse.

The global whistleblower hotline was used as intended and managed as designed. All staff and managers have access to independent and neutral communication channels to report potential non-compliance with laws, regulations, as well as internal and external business standards. No major cases were reported. The number of cases remained almost unchanged from the previous year and is in line with international benchmarks.

Our Code of conduct is one of many tools we provide our employees to help them meet our legal and ethical obligations. It is comprehensive in scope, covering business practice, corporate governance, patient health and safety, conflicts of interest, insider information, competition laws, bribery, gifts and donations, property, equality, records, confidentiality, intellectual property and environmental law. All employees must sign and abide by the Code, which is available in various languages. In addition to the Code of Conduct, our actions are guided by various other policies, including an environmental policy, a quality policy and a staffing policy. In 2011, we launched a global staffing policy and an employee handbook for our HQ in Switzerland.