Records Management

Records Management deserves our due attention

Records Management is understood as the creation, retention and discarding of records.

Many business records, irrespective of their media (paper, electronic, audio/video, microfilm etc.), that Roche employees create or receive in the course of their business are valuable assets for Roche. Therefore, efficient and correct Records Management is crucial for the protection of Roche’s interests.

Roche’s corporate records management program (“COREMAP”) defines standards to improve the management of records across the global Roche organisation.

Roche distinguishes between convenience records and official records. Official records are listed in the Roche Group records classification. They need to be managed in compliance with internal and external standards and regulations, and be kept for a specified period of time. Convenience records are only of temporary value and will need to be regularly disposed to avoid risks and costs.

Roche employees are required to adhere to the following standards of care whenever they create a record:

  • think before writing and decide whether it is necessary to create a record (e.g. an e-mail) at all;
  • make sure that the record is in compliance with applicable laws;
  • be factual, do not make assumptions and avoid misleading and suggestive wording;
  • never create a document for which we would not be prepared to take responsibility;
  • be mindful of the recipients of a record – do not share a record with recipients, especially externally, if there is no need for them to have access to it.

Records that reach the end of their life cycle must be discarded in line with the Roche Records Management Directive, local records management policies and retention schedules.

Records that relate to any actual or imminent legal proceeding or regulatory investigation are subject to compulsory retention and disclosure pursuant to applicable laws (so-called “legal hold” or “law hold”); Roche employees are not allowed to destroy these records and must retain them until such hold is lifted.

We are all expected to:
  • Manage our records with due attention.
  • Never destroy any records that relate to any actual or imminent legal proceeding or regulatory investigation.
Questions & Answers

What is understood by “Records Management”?

A Records Management is understood as the creation, retention and discarding of a record.

Why is it important that I adhere to the Roche standards of care whenever I create a document in my business activities?

Be aware that any document can be used as evidence in a legal procedure or regulatory investigation against Roche; e.g. misleading and suggestive statements may trigger an investigation against Roche as a company as well as against the employee involved.

I have inherited documents and e-mails from my predecessor which could have been destroyed as the legally specified retention period has expired. Now I have heard there is a legal case and I think that the documents could be used against Roche. Am I allowed to discard them?

No. You must not destroy any records that relate to any actual or imminent legal proceeding or regulatory investigation. The discarding of these documents would be considered as obstruction of justice, which is subject to severe sanctions. Therefore, you must preserve the records that could be relevant. Contact the Legal Department for further advice.

Further Informations

Further information and guidance: The Roche Global Records Management Directive, the Roche E-Mail Directive, the e-learning program “Guide to E-Mail Use”, the Roche Guidelines on Competition Law Investigation (“Dawn Raid”) and the video “Your E-Mail Matters” contain further information and guidance on this subject and can be found on the Roche intranet (see website of Group Legal Department).
Help & advice: You can get further help and advice regarding records management from your local Records Coordinator and the Legal Department.
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 records management, speak up by using the available speak up channels.