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 right to be heard as well as 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 subject matter 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.