Bribery & Improper Advantages

We do not tolerate bribery or any other form of corrupt business behaviour

Roche rejects all forms of corrupt business behaviour, such as bribery (public, private, active and passive), embezzlement, fraud, theft and the granting of improper advantages. The Roche Directive on Integrity in Business provides further guidance on these topics.

Bribery

Roche employees and its business partners are not allowed to give, promise to give, solicit or accept any form of improper advantage, whether directly or indirectly, to or from any individual or organisation with the intention to obtain or retain business in return. Improper advantages include illegal rebates, bribes, kickbacks and under-the-table payments. An improper advantage can be anything of value, including but not limited to payments, meals, gifts, entertainment, travel expenses or fake agreements.

Granting of Improper Advantages

Equally prohibited is to give or promise to give an improper advantage without a specific business decision in mind. In contrast to the bribery definition, there is no “service in return”. The improper advantage can therefore be seen as a “goodwill” payment to increase the sympathies towards the giver.

Roche employees have to keep in mind that perception matters and that their behaviour could be considered as a bribe or granting of an improper advantage, regardless of their intention.

These principles apply globally to all public and private business transactions involving Roche. Many countries have laws making it a crime to bribe and/or to grant an improper advantage to public officials. Violation of these laws or other laws that prohibit unfair competitive practices can result in criminal and civil actions against Roche and the individuals involved.

Provided all the requirements as specified in the Roche Directive on Integrity in Business are met and applicable local approvals are obtained, advantages to business partners and other third parties may be permissible.

We are all expected to:
  • Comply with the requirements as set forth in the Roche Directive on Integrity in Business.
  • Not practice, tolerate or in any form support any corrupt business behaviour.
  • Never give, promise to give, solicit or accept any form of improper advantage.
  • Carefully check whether the granting of an advantage is in compliance with Roche’s standards of business integrity.
Questions & Answers

I negotiated a speaker agreement with a healthcare professional (HCP) for a Company oncology event. Before the event, the HCP informs me that he will not be able to come and act as speaker. My Line Manager believes this HCP is important to our business and therefore requests to proceed with the contract to ensure he is paid even though he will not be speaking at the event. What shall I do?

You should immediately inform your Line Manager about your concerns and that you will not proceed with the contract because paying the HCP for services not rendered would be considered a bribe. If your Line Manager insists or asks you to keep quiet, you should immediately contact the local Compliance Officer or the Chief Compliance Officer. Alternatively, you can use the Roche Group SpeakUp Line.

According to local customs it is the socially acceptable practice to give a small gift to a business partner for the new year. Is this permissible?

Yes, provided all the requirements as set forth in the Directive on Integrity in Business are met, as well as the applicable local approvals are obtained.

Is a facilitation payment in the form of a small bribe permissible?

No, according to our Roche Group Code of Conduct and many national laws, any form of bribe, regardless of the amount, is prohibited. Thus, any facilitation payments are forbidden unless such payments can be qualified as permissible advantages.

Further Informations

Further information and guidance: Roche Directive Behaviour in Business – Directive on Integrity in Business; Roche Pharma Directive on Interactions with HCPs and HCOs; Roche Diagnostics Divisional Standard on Interactions with HCPs and HCOs; Roche Good Practice Guidelines on Working with Government Officials; Roche Anti-Corruption Compliance Questionnaire for Roche Business Partners (self-assessment tool); Roche Anti-Corruption Compliance Assurance Confirmation of Roche’s Business Partners; eLearning program “Behaviour in Business - Addendum I” (RoBiB Add I). These materials can be found on the Roche intranet (website of Group Legal Department).
Help & advice: In case of questions regarding bribery and improper advantages, please contact your Line Manager, the local Compliance Officer, the Chief Compliance Officer or the Roche Group Code of Conduct Help & Advice Line.
Speak up: If you believe in good faith that in connection with a business where Roche is involved someone has done, is doing, or may be about to do something that violates the provisions regarding bribery or improper advantages, speak up by using the available speak up channels.