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

It is equally prohibited 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 strict laws and regulations regarding bribe and improper advantages, resulting 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:
  • 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. My Line Manager believes this HCP is important to our business and 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.

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 can be found on the Roche Internet and Intranet. For specific information consult the Roche Directive on Integrity in Business.