Where can I report integrity concerns?
Reports can be made initially to your line manager, local or group Compliance Officer, Compliance Ambassador. In case you suspect misconduct and genuinely believe that the matter cannot be dealt with through the available channels within the organization, you can use the external Speak Up service (EthicsPoint).
Who can report integrity concerns?
All employees and any stakeholder who has a business relationship with Helsinn can report integrity concerns.
What type of concerns ca be reported?
All Helsinn Code of Conduct and Third-Party Code of Conduct and Ethics violations should be reported, including but not limited to:
– Ethics and compliance issues, fraud, misconduct, corruption, financial issues, conflicts of interest, insider trading, bribery, disclosure of confidential information
– Employee relations and human resources issues, such as harassment, discrimination, improper workplace conduct
– Violations of competition laws and rules
– Inadequate financial or non-financial recordkeeping
– Environmental, health and safety issues
– Improper use of company resources
– Violations of our policies on gifts, entertainment and hospitality
Shall my report remain confidential?
All reporting is done confidentially. This means that information about your concern will only be shared with a limited number of people on a strict need-to-know basis. Information will only be disclosed outside this small group if we are required to do so by law or an important public interest is at stake. In principle, we are obliged to inform the implicated person that a complaint has been filed against him/her, but your identity will not be disclosed.
What type of information should I include in my report?
When you file a report in person, in writing, online or by phone, please provide as much detailed information as you have to enable Helsinn to assess and investigate your concern, such as:
– The background, history and reason for the concern
– Names, dates, places and other relevant information
– Any documents that may support your report
A report can only be followed up if it contains sufficient information and there is a reasonable possibility of obtaining further information
Who will investigate my report?
All concerns that are received by Helsinn are logged into a case management system. Depending on the nature, urgency and potential impact of your concern, the case will be handled by the local or Group Compliance Officer (the “Case Manager”) who works under the supervision of the Board of Directors. If the case involves the local Compliance Officer, the system is set to automatically deprive her/him from the handling of the particular case and the management system notifies by default the Group Compliance Officer only. In the instance that the case involves the Group Compliance Officer, the system is set to automatically deprive her/him from the handling of the particular case and the management system notifies by default the Group General Counsel.
Who determines the appropriate disciplinary action to resolve my issue?
If the concern is well-founded, a disciplinary committee decides the appropriate measures to be taken in accordance with applicable laws, Helsinn Disciplinary policy and Helsinn General Working Conditions policy.