Addressing Non-compliance

Adequate handling of non-compliance cases is a key part of our comprehensive compliance management

Roche does not tolerate non-compliant behaviour. Employees and Line Managers who violate the Roche Group Code of Conduct will be held accountable.

Roche is fully committed to handling non-compliance cases adequately by:

  • taking all allegations seriously;
  • investigating allegations efficiently and in a timely manner;
  • assessing the facts objectively and impartially; and
  • taking adequate corrective measures and sanctions, in case an allegation is substantiated.

Any accused employee enjoys the presumption of having acted in accordance with the Roche Group Code of Conduct, unless the evidence gathered from the investigation reasonably indicates non-compliance. We fully collaborate with the investigators and make sure that we have compliance evidence at hand, which demonstrates that our behaviour was compliant.

Certain allegations, in particular but not limited to corporate bribe and fraud, will be investigated by internal or external experts under the leadership of the Roche Group Audit and Risk Advisory Department.

Line Management with the support of Human Resources and local Compliance Officers is responsible for determining adequate corrective measures and sanctions.

Non-compliance cases have to be reported under the responsibility of specified Line Managers in the Business Ethics Incident Reporting (BEIR) system as soon as they become aware of them.

The BEIR system enables 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.

The number and related characteristics of non-compliance cases which occurred during a reporting year will be published in the annual report of Roche Holding Ltd.

We are all expected to:
  • Make every effort to prevent non-compliance cases.
  • Fully collaborate with the investigator and ensure we have compliance evidence at hand.
  • Take adequate corrective measures and sanctions if we have to handle non-compliance cases as a Line Manager.
Questions & Answers

Does Roche tolerate violations of its Group Code of Conduct?

No. Violations of the Roche Group Code of Conduct are not tolerated and responsible employees will be held accountable. Under the responsibility of Line Management adequate corrective measures and sanctions must be taken.

What is meant by “compliance evidence”?

Compliance evidence is any form of proof demonstrating that your behaviour was correct, e.g. written evidence of the consent of your Line Manager in a possible conflict of interest situation.

What shall I do if my Line Manager insists that I undertake something which I consider not in line with the Roche Group Code of Conduct? Is it sufficient compliance evidence if I make a note stating that the Line Manager has insisted on my acting accordingly?

No. If your Line Manager is insisting on incorrect behaviour you should speak up by using the available speak up channels.

Further Informations