Compliance, Ethics and Transparency

It is our fundamental responsibility to act with integrity and maintain the highest ethical standards in everything we do. Our aim is to build trust and give confidence to patients, employees, partners and the communities we serve.

Our culture and compliance system provide a clear framework for our actions and are built around our Code of Conduct. Our Compliance Organisation is deeply anchored in our business. Compliance Officers sit on decision-making bodies across the organisation. Their independence is maintained through a direct reporting line into the Chief Responsibility Officer, who regularly reports to the Executive Board and the Supervisory Board.

An ongoing dialogue at Grünenthal brings to life our global Compliance framework. This includes face-to-face training and workshops, as well as online training sessions and day-to-day consulting for our colleagues. We firmly demand that our business partners act lawfully and with integrity in line with this framework. We also offer a 24-hour Ethics Helpline that is open to anyone who has questions, concerns or doubts.

Two female Grünenthal employees walking in a floor in conversation with each other

Grünenthal General Counsel Sebastian Köhler talking to an employee

Grünenthal Head Global Communication talking to an employee

Material Topic	Our Ambitions / KPIs for 2022
Compliance, Ethics and Transparency	Continuous development of our state-of-the-art compliance and ethics framework that was globally re-launched in 2018 (e.g. by establishing a bioethics and data ethics framework in 2021).
	Establishing and constantly improving a working environment where all employees feel valued, respected, included and empowered to do their best, bring great ideas to the table and develop their full potential.
Product Governance and Safety	97 percent “on-time” submissions to authorities globally for Individual Case Safety Reports (“ICSR”).
	Maintain or exceed the current level of recognised compliance with global pharmacovigilance standards. 100 percent compliance with the International Conference on Harmonisation-Good Clinical Practice (ICH-GCP) standards and other applicable ethical standards.

Compliance

The Grünenthal Code of Conduct sets out our commitment to the highest ethical standards. Everybody in our organisation has the responsibility to live up to these standards in their daily work. All employees sign the Code of Conduct when joining Grünenthal.

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We are committed to ethical business practices, and we only work with business partners who uphold the same high standards for themselves as we do. To ensure this, we established our Code of Conduct for Business Partners, which must be signed before formally entering into a partnership.

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We encourage everyone to report any questions, doubts or suspicions they may have through our Ethics Helpline. The confidential internet-based platform can be used 24/7. Every complaint or concern is investigated by our Compliance Organisation. Where appropriate, action is taken.

Ethical Business

Grünenthal’s Charter on the Responsible Use of Opioids sets out our commitment to exploring and endorsing measures that minimise the risk of inappropriate and illegitimate use of prescription opioids – while striving to ensure that individual patients with a clear need for opioid-based pain relief are not denied access.

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We are committed to conducting business in a legal, ethical and honest manner. We have a strict Anti-Corruption Policy, a Fair Market Value tool and strict approval processes for transfers of value in place to ensure that we do not tolerate corruption in any form.

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We handle all personal data responsibly. We conduct all of our data processing activities in line with applicable legal standards such as the GDPR, and we also adhere to the principles laid out in our Digital Ethics Charter and Data Protection Policy.

We are committed to conducting our research activities within a strict bioethical framework. We adhere to clear rules on animal trials, human biological sampling and emerging technologies.

Transparency

We will share clinical information that is necessary for conducting legitimate research, serving patients’ safety and improving public health. We have publicly committed to the Principles for Responsible Clinical Trial Data Sharing that were issued in January 2014 by the European Federation of Pharmaceutical Industries and Associations (EFPIA) and the Pharmaceutical Research and Manufacturers of America (PhRMA).

We are a member of the European Federation of Pharmaceutical Industries and Associations (EFPIA) and support the EFPIA Disclosure Code. We are committed to publishing information about our collaboration with healthcare professionals (HCPs) and healthcare organisations (HCOs) to demonstrate that we interact with these stakeholders in an ethical and transparent way.

All interactions and transfers of value are disclosed in line with local regulations. These disclosures are aligned with either the EFPIA Disclosure (Transparency) Code of Conduct, local pharmaceutical codes or national legislation implemented by organisations such as healthcare authorities. The underlying rationale and methodology follow a coherent concept.