Our Compliance Action Line

There are several ways one can do so: Employees can reach out to their managers or their superiors or to specialists in functions such as Compliance, Legal or Human Resources.

We have also set up an external hotline system – called the Compliance Action Line  – operated by an independent, certified third-party vendor for our employees and related third parties to report potential violations of laws or company guidelines.

Reports can be made confidentially and, if desired, anonymously, where legally permitted. The system is available 24 hours a day and reports can be made by telephone (using the toll-free number for your country) or by electronic platform in several local languages.

In 2021, around 3,000 reports were received and processed by the responsible departments. In North America, our hotline is set up to report compliance concerns. However, we also receive non-compliance related calls on patient care, information security reports, and human resources. These calls are forwarded to the appropriate departments. 

Each report is documented and reviewed based on more than 30 allegation categories. The reports covered topics such as anti-corruption, data protection, and human resources/workplace. We investigate all cases of potential misconduct, take corrective measures on a case-by-case basis, and track their implementation. Of 106 compliance investigations in 2021, about half were found to be actionable. Actionable means that the investigations established findings that led us to improve processes, adjust policies or internal controls, or disciplinary action.