Maintaining an Ethical and Compliant Business
Conducting business with integrity and transparency is non-negotiable for Teva. Our compliance vision is for business to be gained the right way, not by any means necessary. As our Chief Compliance Officer says, "What we do is important, but how we do it is just as important. Let’s continue to do business the right way, the ethical way…our way.”
Robust Governance: At Teva, compliance and ethics is everyone’s responsibility. Over the last six years, Teva has strengthened our compliance and ethics program across the globe, with an emphasis on policies, training and support that meets the business in areas related to compliance. Our Chief Compliance Officer reports directly to our CEO, and the Compliance Committee of Teva’s Board of Directors oversees our policies and practices for legal, regulatory and internal compliance and reviews relevant policies and practices. Our Global Compliance & Ethics (GC&E) department is structured to ensure our business partners have a consistent and dedicated partner at all levels of work.
- Guiding Policies and Code of Conduct: One of the ways in which we cultivate a culture of compliance and accountability is by ensuring our values are reflected in our policies and procedures. Primary among these is Teva’s Code of Conduct, which outlines our values and foundational compliance and ethics expectations for all employees. Equally important is Teva’s Policy on the Prevention of Corruption, which details Teva’s anti-corruption and anti-kickback approaches, guiding how we collaborate and interact with other members of the healthcare ecosystem.
- Strategic Compliance Training: Our risk-based global compliance training and communications program strategically assigns risks to each role at Teva, and employees receive relevant compliance trainings. Upon hiring, each employee receives extensive Code of Conduct training, followed by refreshers and updates every three years.
- Fostering a Culture of Compliance: We strive to create a culture of integrity and compliance throughout our company. Our Board members and senior management communicate frequently about the importance of doing work with integrity and gaining business the right way. Our training is designed to foster an appreciation of the responsibility everyone shares, not only to do the right thing, but to speak up if they see something wrong. We have developed comprehensive compliance mastery training for senior leaders at the company, which provides tools to effectively embed compliance and ethics into their work. These efforts have been successful, as our recent survey indicates employees have strong, favorable perceptions of Teva’s culture of integrity.
- Compliance Systems and Processes: An effective compliance program requires more than just individual integrity; it also requires the tools necessary to translate that integrity into an effective system of controls. Our compliance processes and systems help identify potential indicators of risk in our day-to-day business and mitigate them, as appropriate. In recent years, we have collaborated with several other functions at Teva, including finance, internal audit and IT, to ensure our compliance function has the necessary tools. This includes ensuring we have adequate systems in place for tracking and reporting payments to members of the healthcare community, ensuring the integrity of our books and records, undertaking effective monitoring of activities and directing our auditing and remediation efforts towards the most important subjects and areas of the company.
- Addressing Compliance Issues: We are committed to conducting business ethically and responsibly. In cases of missteps or perceived missteps, we revisit our processes and seek to strengthen our compliance mechanisms to reduce risks. Central to our ability to address these concerns is our Office of Business Integrity (OBI), which operates our global compliance hotlines and investigates all allegations of misconduct. The OBI empowers employees to speak up on issues of potential concern and provides us with important information to address concerns.
Policies and Positions
"What we do is important, but how we do it is just as important.”
Teva’s Compliance and Audit Committees of the Board of Directors oversee our compliance activities. Compliance Committee members meet at least four times a year and report to the Board. The Compliance Committee oversees our policies and practices for complying with laws, regulations and internal procedures; policies and practices regarding issues that have the potential to impact our business and reputation; global public policy positions and government affairs activities; and our environmental, social and governance (ESG) strategy.
In 2015, GC&E became a standalone function at Teva, with our Chief Compliance Officer reporting directly to our CEO and to the legal counsel and overseeing nine regional compliance officers responsible for various functions. The GC&E group is organized into five core teams that support the main areas of Teva’s business, including Commercial, R&D, Teva Global Operations (TGO) and Medical. Our Chief Compliance Officer regularly attends and participates in Compliance Committee meetings and has unencumbered access to members of the Board. The GC&E department has a combined 1,080+ of pharmaceutical experience and 700+ years of compliance experience.
Guiding Policies and Code of Conduct
Teva’s Code of Conduct codifies our ethical standards and expectations for our employees across numerous subject matter areas. It has been translated into more than 40 languages. Each provision in the Code is centered on our values and designed to explain and identify areas in which acting in accordance with our values is particularly important.
Each employee at Teva is provided a copy of the Code of Conduct upon hiring, along with extensive initial training, and receives periodic refreshers and updates every three years.
Our Policy on the Prevention of Corruption details Teva’s anti-corruption and anti-kickback rules for all employees. They guide how we collaborate and interact with other participants in the healthcare ecosystem, including governmental and non-governmental organizations, scientists, healthcare professionals, trade and industry associations and patient groups. They specifically prohibit bribing or offering, providing or promising anything of value (directly or indirectly) that is intended to improperly influence the action of government or private individuals.
Strategic Compliance Training
Teva has a risk-based global compliance training and communications program. Every role at Teva is assigned a risk designation based on interactions with members of the healthcare community or government officials, and the personnel in those roles receive relevant compliance trainings. Teva’s compliance and ethics trainings are integral to our employees’ education and awareness. Core curricula include principles-based live or web training, including policy certification. This is complemented by ethical behavior-based web training.
Over the last four years, we have launched four training campaigns and more than ten modules, outlined below. Each campaign includes multiple modules, and employees are assigned courses based on their risk designation.
Fostering a Culture of Compliance
We promote a culture of integrity and compliance through messaging campaigns and other initiatives, including our new ethics messaging resource library for managers.
Our 2021 organizational health survey of 32,860 employees (82% of all employees) found:
- 83% believe Teva is living up to high ethical standards (vs. 80% benchmark)
- 79% believe if they had to report unethical behavior or misconduct, they would feel confident that it would be handled effectively by the company (vs. 77% benchmark)
Our 2021 survey of more than 14,500 colleagues found that employees:
- Observe low rate of misconduct (7% vs. 12% benchmark)
- Perceive Teva as responding quickly to reports and having zero tolerance for unethical behavior (77% vs. 75% benchmark)
- Perceive a more positive “tone from the top” (senior leaders) (75% vs. 73% in 2019)
- Feel open sharing information and opinions on important issues with colleagues and direct reports (69% vs. 67% in 2019)
Compliance Systems and Processes
We have processes and compliance mechanisms in place to improve risk management and identify issues related to corruption.
- Risk Management: We routinely assess and remediate compliance risk for all operations that have touchpoints with healthcare professionals or government officials. This includes geographies where we have commercial, manufacturing and R&D operations, as well as areas where we work through distributors. We manage risks based on robust internal and external data. Risk ratings determine how much we monitor, with higher risk ratings associated with greater monitoring efforts. As risks evolve or increase, we adapt by increasing our monitoring activity. We monitor trends and changes in the external environment, such as enforcement action or new laws, to continuously refresh trainings and promote integrity and ethics.
- Office of Business Integrity: Under our Code of Conduct, all Teva employees are encouraged to speak up if they suspect improper conduct. The Office of Business Integrity (OBI) is a dedicated team at Teva charged with objectively and confidentially investigating reports of misconduct that violate our Code, values, policies or laws. Employees can contact the OBI through a designated email address or make a report through the Teva integrity hotline, which is available in more than 60 countries. All reports are preliminarily assessed within 48 hours of receipt, and certain issues, including quality or safety concerns, are immediately escalated. The OBI conducts all investigations in a confidential manner and provides periodic updates and the final report to relevant management, HR and legal, as needed. HR and applicable management take appropriate corrective actions, in light of all relevant facts and circumstances identified during the investigation. The OBI ensures that decisions concerning corrective actions are applied in a consistent manner. These may include, among other steps, coaching, policy/process review, reprimands, warnings, termination and vendor disengagement. The OBI provides regular summary reports to key stakeholders, including the Audit Committee, and analyzes trends and identifies potential areas for improvement and lessons learned.
Addressing Compliance Issues
At Teva, we constantly monitor civil and criminal enforcement trends to ensure our policies, procedures and systems are designed to identify and remediate the risks that government authorities expect corporate compliance programs to focus on.
- Compliance Monitor: In 2016, Teva resolved certain claims under the US FCPA with the Securities and Exchange Commission (SEC) and US Department of Justice (DOJ). The settlement included retention of an independent compliance monitor for three years.
- Following Teva’s certification to the SEC and the DOJ confirming Teva had complied with disclosure obligations, the information was dismissed in July 2020.
- Since the initiation of the monitor, Teva has participated in two global internal audits and conducted eight Teva affiliate site visits. We also initiated other compliance mechanisms, including a cultural assessment survey to measure progress, review of our commercial policy, implementation of the shadow disciplinary process, proxy testing of enhanced internal controls, third party due diligence system testing and general manager mastery compliance training program.