The Roche Group Code of Conduct states the expectations Roche has as an employer towards employees and sets forth the standards for business behaviour that apply throughout the Roche Group.

All employees and all others acting on behalf of Roche must comply with the Roche Group Code of Conduct, regardless of their location and the nature of their work. Also, following the “One Roche Approach” principle, the set forth standards are equally binding for Group Functions, the Pharmaceutical and the Diagnostics Division.

The Roche Group Code of Conduct is built on the Roche Values. The code contains guidance in the areas of products and services, personal integrity, corporate integrity, employment, company assets, responsible business and comprehensive compliance management. It also provides questions and answers, examples and information on where to find more detailed guidance on the various topics. Roche employees, as well as business critical business partners, are trained on the key compliance principles by a global mandatory eLearning. The eLearning focuses on the following topics: bribery & improper advantages, gifts & entertainment, conflict of interest, discrimination & harassment, responsible use of social media & electronic communication tools, and business partners & supply chain. All employees are required to complete this eLearning when they join Roche, as well as when the Roche Group Code of Conduct gets updated every 5 years. In 2021 the completion rate of Roche employees was 98%.

Roche is corporate member of numerous pharma and diagnostics/medical device associations and adheres to the selfregulating Code of Conducts, including IFPMA, EFPIA, MedTech Europe, APACMed, MecoMed. Also on local level, Roche Affiliates are often member of the local associations, as for example interpharma, scienceindustries, Advamed US, Advamed China.

Anyone who becomes aware of a potential violation of the Roche Group Code of Conduct can and should bring it to the attention of their line manager or supervisor, to the local Compliance Officer or the Chief Compliance Officer (Pascale Schmidt, direct phone number: +41 61 688 48 90).

Roche employees can also use the following reporting channels:

  • The Roche Group Code of Conduct Help & Advice Line in case of compliance questions or uncertainties

  • The Roche Group Speak Up Line to report in good faith a suspected violation, including a person they believe has done, is doing or may be about to do something that violates the Roche Group Code of Conduct. Launched in 2009, the system comprises a web and telephone service that enables employees to report compliance concerns confidentially and anonymously. The SpeakUp Line operates in 103 countries and 53 languages, making it available to over 80,000 employees. All reports will be treated as confidential and the reporting employees will not be penalised by the company for doing so, however, they are not immune from prosecution for legal violations.

Roche takes all non-compliance reports seriously and is fully committed to efficiently and timely investigate them, to assess the facts and, if necessary, to take adequate corrective measures and sanctions.

Our Business Ethics Incident Reporting (BEIR) system enables the Top Management, the Chief Compliance Officer and the Chief Group Audit and Risk Advisory Executive to capture, track and monitor alleged violations, from initial reports through to resolution.

In 2021 we received 567 reports relating to alleged violations of the Code of Conduct. The vast majority of the reports related to personal integrity cases, such as expense fraud, conflict of interest, abuse of company assets, harassment and discrimination. Out of 567 cases, 214 were unfounded, 216 were founded and 137 were still under investigation. The amount of unfounded allegations is based on the internal requirement that allegations need to be reported immediately in the BEIR system, if and when the management has received information about an allegation.

On the grounds of unethical behaviour, 88 employment contracts and 8 agreements with business partners were terminated. Further sanctions of unethical behaviour of employees included warning letters, bonus reduction and downgrading of position. Also were appropriate corrective measures taken, such as coaching and trainings.

Setting forth the standards for business behaviour that apply throughout the Roche Group.

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