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Reporting Channels

In the case where it is observed a conduct that seems to violate laws, Helsinn Code of Conduct and/or Helsinn policies and procedures, employees should first address it with the person involved or through the regular reporting lines. In cases where the regular reporting lines would not be sufficient or adequate to the situation, Helsinn offers a variety of ways to report suspected or actual violations, including anonymous reporting options available at the EthicsPoint – Helsinn Group. By doing so, it’s given to Helsinn the opportunity to deal with the issue.

Remaining silent about possible misconduct may worsen a situation and decrease trust.

Helsinn truly values the help of employees who identify and Speak Up about potential concerns that need to be addressed. Speaking Up is encouraged and employees who Speak Up, genuinely and in good faith, are protected. There will not be any consequences for you for raising concerns in good faith about suspected misconduct. Helsinn does not tolerate any form of retaliation against you for Speaking Up.

Speaking Up is essential for us to sustain our reputation, success and ability to operate, now and in the future. In fact our Code of Conduct states that all employees are required to bring actual or suspected cases of misconduct to the attention of the Group Compliance Officer or to the attention of the Local Compliance Officer, whether they are directly involved or they are only witness of actual or suspected violation.

Misconduct consists of any conduct that infringes laws, our Code of Conduct, pertinent policies, procedures and/or external laws or regulations.

Examples of concerns that can be raised include, but are not limited to:

Accounting

Any intentional misrepresentation of information, undue influence or concerns of a lack of independence relating to interactions with external or internal auditors, or the oversight of audit functions of activities, including questionable practices relating to accounting, auditing or internal financial controls (examples include: tax evasion, misstatement of revenues, misstatement of expenses, misstatement of assets, misapplications of accounting principles, wrongful transactions).

Bribery

The act of influencing the action of another by inducements which may include giving items that could be reasonably interpreted as an effort to corrupt of otherwise improperly influence a business relationship or decision.

Financial Issues

The alteration, fabrication, falsification, or forging of all or any part of a financial document, contract or report; the creation of misleading impressions, omission of important facts, or making false claims; inaccurate financial disclosures, insider trading, or questionable practices relating to internal financial controls.

Violation of Code of Conduct

  • Discrimination or harassment
  • Improper Interactions with HCPs/Patients/Authorities/other Stakeholders
  • Fraud
  • Violations of competition laws and rules
  • Improper use of company resources

Violation of Helsinn Policy

  • Conflicts of interest
  • Insider trading
  • Disclosure of confidential information
  • Violations of our policies on gifts, entertainment and hospitality

Environmental, health and safety issues

The violation of the laws, rules, practices and processes designed to help protecting employees, the public and the environment from harm.

Violation of local policies and guidelines related to expense reporting, interaction with HCPs and compliance directives.

How To Report

Confidentiality, Personal Data Protection and Non Retaliation

Every reports is handled as strictly confidential and in full compliance with the applicable national and international laws and regulation on personal data protection and privacy, as set forth by the relevant Helsinn policies and standard operating procedures, such as in particular the Group Data Protection and Privacy and the Group Employee Data Protection Notice.

Information about a concern will only be shared with a limited number of people on a strict need-to-know basis. In principle, we are obliged to inform the implicated person(s) that a concern has been filed against him/her, but the information provided will be the minimum to frame the situation and the identity of the reporting employee will not be disclosed.

The reporting employee shall be expected to also be discreet and not discuss the report with colleagues or anyone else.

Helsinn has a strict Non-retaliation Policy protecting anyone who submits a report in good faith. Any employee who raises a potential case of misconduct in good faith acts in the interest of Helsinn and deserves acknowledgment. Employees who report in good faith potential violations, who provide information or otherwise assist in any inquiry or investigation of potential violations, will be protected against retaliation. Self-reporting does not immunize a reporting employee from the consequences of his or her own misconduct. However, the act of coming forward is considered when determining actions/remediations (e.g. mitigation of remediation).

The necessary steps will be taken to protect and to guarantee the anonymity of the reporting employee. However, this cannot be ensured in all cases, (e.g. when the investigation reveals conclusions which the company determines should be disclosed to an authority).

Every compliance concern will be taken seriously. Allegations not made in good faith, (e.g. with malicious intent to harm another employee) are considered a violation and will not be tolerated.