Ethics & Compliance Program

Strong Leadership

At AbbVie, all employees are expected to lead and foster a culture of ethical and compliant behavior. To assist us, AbbVie has an Office of Ethics and Compliance (OEC), which focuses on the development and enhancement of our compliance program. OEC is led by our Chief Ethics and Compliance Officer (CECO), who is a member of our senior management and makes regular reports regarding compliance matters to the Chairman of the Board and Chief Executive Officer, other senior-level leaders and AbbVie’s Board of Directors and Public Policy Committee. The OEC staff provides dedicated support to AbbVie’s leaders, employees and businesses.

To assist in the implementation of the Global compliance program, AbbVie has a Business Conduct Committee (BCC). This committee is chaired by the CECO, include senior-level leaders, and are accountable directly to the Chairman of the Board and Chief Executive Officer. The BCC holds periodic meetings to discuss compliance matters within its charter, including adherence to legal and regulatory obligations and commitments, assessment of our compliance programme, changes in the legal and regulatory environment, risk areas and best practices, and improvements to the program.

For Australia specifically, our Australian Compliance Programme is managed by our Australian Compliance Steering Committee, which is composed of the General Manager and other top executives within Australia. Working with OEC staff, the Australian Compliance Steering Committee is responsible for the day-to-day function of the compliance programme, including monitoring of compliance, providing awareness of and training for the programme, revising policies and procedures and providing guidance to local employees. The committee meets on a regular basis to discuss emerging issues and work with the OEC staff as new compliance and awareness programs are rolled out.

Clear Written Standards

The Code of Business Conduct, published in print and online, sets forth core guidelines and requirements for ethical behavior. AbbVie employees read and certify adherence to our Code annually. Our Code states clearly that AbbVie does not tolerate illegal or unethical behavior in any aspect of our business. It emphasises the importance of ethical and honest conduct, adhering to AbbVie’s policies and procedures, treating confidential information appropriately, avoiding conflicts of interest and maintaining AbbVie’s books and records with accuracy and integrity. Further, it requires our employees to ask questions about or report any concerns regarding compliance matters.

In addition to our Code, we have policies and procedures that guide employees as they conduct their day-to-day activities. They encompass relevant laws and regulations, including food and drug laws and laws relating to government health care programs. They also take into account industry best practices, including provisions of the International Federation of Pharmaceutical Manufacturers & Associations (IFPMA) Code of Pharmaceutical Marketing Practices and the Pharmaceutical Research and Medicines Australia Code of Conduct, as well as other applicable industry codes. We regularly update our policies to incorporate changes to the law and industry codes, including rules regarding gifts, meals and education we provide to health care professionals.

AbbVie also complies with legal, industry and relevant institutions’ requirements regarding the interaction of our employees with health care professionals and organisations. We comply with national, regional, state and other requirements regarding transparency about our relationships with individuals and entities involved in providing health care. As required, we track and report payments and transfers of value (such as meals) provided to health care providers and organisations.

Effective lines of communication

Creating an environment where employees can raise questions and concerns helps us advance our commitment to ethical behavior. We have established systems and processes for employees and others to ask questions, raise concerns and report suspected or actual violations of our Code, policies and procedures, or laws and regulations, without fear of retribution or retaliation. We offer a number of resources to employees, such as our Ethics and Compliance Helpline, a telephone- web-based hotline. Employees also may contact the OEC or the CECO directly.

All allegations are analysed and corrective actions are taken where necessary, including terminating employee contracts or supplier relationships. In accordance with our internal or legal obligations, we report information about actual or potential violations to senior management, the Board and the government(s), as appropriate. The OEC also creates opportunities to engage in face-to-face interactions with employees by participating in national, regional and local meetings.

Relevant Training

Training and education programmes for employees and other relevant personnel increase their awareness of our Code’s principles and the legal and ethical implications of their actions and behaviours. AbbVie’s ethics and compliance staff work with our commercial teams to help them conduct trainings and education programmes that help ensure compliance and strengthen AbbVie’s reputation as a responsible corporate citizen while enhancing relationships with customers and other stakeholders

Accountability

AbbVie employees and other relevant personnel are expected to adhere to our Code as a condition of their continued employment. Anyone who violates our Code, or any policy or procedure, is subject to appropriate disciplinary action. Any AbbVie employee who fails to report a violation of AbbVie policy or procedure of which he or she is or should have been aware may also be subject to disciplinary action. AbbVie does not tolerate retaliation against anyone who makes a good-faith report regarding a violation or potential violation of our Code, policies or procedures, or laws or regulations. These guidelines are well publicised and enforced.

Continuous Improvement

The OEC utilises results from internal investigations, internal audits and internal monitoring programs to assess the effectiveness of, and identify areas for improvement in, the compliance programme and relevant business practices. In addition, we consider the external environment, including government investigations, settlements, industry codes and government guidance to identify new opportunities to enhance the compliance program. When an area for improvement is identified, the OEC and other AbbVie functions partner to implement corrective actions.