Conducting business with integrity and transparency is non-negotiable for Teva. At Teva, what we achieve is important, but how we achieve it is just as important. We want to succeed the right way, not by any means necessary.
- Compliance and Ethics Strategy: Teva’s compliance and ethics strategy encompasses the following recognized standards and best practices:
- Commitment from senior management and a clearly articulated policy against corruption,
- A Code of Conduct and compliance policies and procedures,
- Oversight, autonomy and resources,
- Compliance training, communication and continuing advice,
- Third-party due diligence management, including for mergers and acquisitions,
- Compliance risk assessments and monitoring,
- Confidential reporting of misconduct or concerns; internal investigation, analysis and remediation of misconduct; appropriate remediation and disciplinary measures, and
- Continuous improvement of the compliance program through benchmarking, surveys and internal and external business analyses
The following summarizes how Teva implemented these standards and best practices into its compliance and ethics program:
- Governance and Resources: Teva’s management is committed to operating ethically and our robust compliance policies, trainings, tools and resources support compliant and ethical business practices. These include a Code of Conduct and policies and programs related to the prevention of corruption, third party management and data privacy. The Chief Compliance Officer has a reporting line to Teva’s Chief Executive Officer (CEO) and direct access to the Compliance Committee, part of Teva’s Board of Directors. The latter oversees Teva’s compliance and ethics program. The Global Compliance and Ethics (GC&E) department has local, regional and functional compliance professionals deployed throughout the company.
- Compliance Training, Communication and Advice: GC&E assigns each new employee the Code of Conduct training and additional courses based on the employee’s risk-based job classification. GC&E has annual training campaigns targeting relevant populations of employees using the same risk-based approach. For all employees, recertification on the Code of Conduct occurs every two years. GC&E also conducts Compliance Mastery Training tailored for management teams and ad hoc compliance trainings for other teams and individuals as requested or needed.
Teva communicates about compliance through various channels, including: formal departmental announcements, Teva’s intranet and the GC&E website, company town hall presentations and newsletters, screen reminders and desktop screensavers, targeted written guidelines and e-mail reminders.
GC&E provides compliance advice at business meetings, local and regional compliance committees, senior management and Board meetings and in frequent interactions with business colleagues throughout the normal course of business.
- Compliance Risk Assessment, Monitoring and Systems: GC&E assesses compliance risk from many sources. These sources include regulatory guidance, new or changed legislation, internal and external audit reports, business monitoring analyses, advice from internal and external legal colleagues, results of employee and compliance surveys, case analyses from the Office of Business Integrity, and benchmarking data on risk and best practices supplied by external consulting firms.
To assess and remediate compliance risk, Teva has an activity approval tool for business colleagues to submit, obtain approval and document compliance-related activities, including interactions with government officials and members of the healthcare community. Teva has a monitoring system to identify and evaluate compliance-related activities. GC&E analyzes monitoring results to determine risks and trends, advise business colleagues, recommend process improvements and guide and develop subsequent risk assessments and monitoring plans.
Two additional tools support compliant and ethical behavior. The first is a due diligence tool developed to manage third-party risk using a vast, regularly updated database of publicly available information on third parties. Using proprietary algorithms, Teva helps business sponsors identify and remediate relative risk of engaging with third parties. The second is an industry-standard data privacy platform to manage data privacy risk. This allows Teva to process and control personal data appropriately.
GC&E assesses sanctions and trade control risk using industry standard sanction screening tools. GC&E works with procurement and finance colleagues to enhance the standard “procure to pay” process to ensure Teva evaluates third party representatives before formal engagement. GC&E also ensures systems are in place to track and report transfers of value to members of the healthcare community.
- Reporting and Addressing Compliance Issues: Central to Teva’s ability to report and address concerns is the Office of Business Integrity (OBI), which operates the Teva’s Integrity Hotline and investigates allegations of misconduct. The OBI empowers employees to speak up on issues of potential concern and provides Teva with important information for management to remediate issues, implement process improvements and make decisions on disciplinary measures. For additional information please see Teva's Integrity Hotline Complaints Procedure.
- Fostering a Culture of Integrity: We strive to create a culture of integrity and compliance throughout our company. Our Board members and senior management communicate the importance of doing work with integrity and obtaining business the right way. We design our training to highlight the responsibility we all share for compliant and ethical behavior, and we encourage employees to speak up if they observe potential misconduct or fraud. We recently redrafted key policies to simplify language for ease of understanding and developed an internal, interactive Code of Conduct to enhance employees’ ethical decision-making. We also created a compliance and ethics resource library of tailored messages for managers to use in communication channels and team settings.
- Recent surveys indicated employees have favorable perceptions of Teva’s culture of integrity.
Policies and Positions
"What we do is important, but how we do it is just as important.”