Ethics and Transparency
Ethics and Transparency
While our CSL Values serve as the directional compass of our work, our Code of Responsible Business Practice (Code) provides a more detailed map to deliver on our promise to patients and public health in ways that exemplify the highest standards of conduct throughout the organisation. CSL’s Code fosters a culture that rewards high ethical standards, personal and corporate integrity and respect for others.
All employees are required to undertake training on the Code and CSL’s new ethics-based decision-making tool. These two e-learning modules were made available in 14 languages to cater to CSL’s global workforce.
In June 2021, CSL published its Third Party Code of Conduct (Third Party Code). The Third Party Code complements CSL’s Code, adopting the Pharmaceutical Supply Chain Initiatives Principles (including international labour standards drawn from international human rights conventions).
The Third Party Code sets out our expectations for the conduct of CSL business by third parties, including suppliers and is available in multiple languages for suppliers and workers.
In accordance with the Code, CSL is committed to ensuring that employees, contractors, suppliers and business partners are able to raise concerns regarding any potential misconduct and to have such concerns properly investigated. This commitment is implemented through CSL’s Speak Up Policy. The Speak Up Policy contains mechanisms, including a global 24/7 telephone and internet hotline service, for employees, contractors, suppliers and business partners to raise concerns in a confidential and anonymous (where permissible by law) manner without being subject to any form of detriment or retaliation.
The Board, together with the Audit and Risk Management Committee (ARMC), has oversight of matters reported under the Speak Up Policy. The Board and the ARMC receive periodic updates, including any material incidents reported under the Policy as well as other information related to the effectiveness of the Speak Up Policy across the Group.
The way in which pharmaceutical companies interact with healthcare professionals is an important issue for the industry. In addition to laws and regulations governing marketing practices, pharmaceutical industry organisations around the world have established various codes of conduct to govern these interactions. Our practices are informed by these codes and their underlying ethical principles. We are committed to complying with all applicable local laws and regulations in each country we operate in.
Marketing in the pharmaceutical industry takes many forms and may include:
- sponsoring conferences and medical seminars;
- sponsoring healthcare professionals to speak at conferences and medical seminars; and
- sponsoring trips for healthcare professionals to attend conferences or medical meetings.
We consider each interaction carefully, with an emphasis on ensuring that our products and services are represented truthfully, fairly and accurately and in full compliance with all applicable laws and codes of conduct. We have policies and compliance training programs in place to ensure that relevant employees understand their own and CSL’s obligations in relation to marketing to healthcare professionals.
Further, internal compliance mechanisms and control systems are directly supported by our Global Ethics and Compliance team and subject to additional oversight by CSL’s Global Compliance Committee (GCC), regional committees, and CSL’s Audit and Risk Management Committee of the Board.
Anti-Bribery & Anti-Corruption
CSL has no tolerance for acts of bribery and corruption by any of our employees, officials or third-party representatives. CSL has an Anti-Bribery and Anti-Corruption Policy (ABAC Policy).
CSL has training programs for employees across the CSL Group to raise awareness of CSL’s ‘zero tolerance’ of bribery and corrupt business practices at any level within CSL’s global operations.
CSL carries out an annual Anti-Bribery and Anti-Corruption Risk Assessment (ABAC Risk Assessment) across the CSL Group with the goal of ensuring compliance with global anti-bribery and anti-corruption laws including, for example, the United States Foreign Corrupt Practices Act and the UK Anti-Bribery Act. Use of this tool keeps the business proactively aware of external enforcement initiatives related to CSL’s business locations and the third parties CSL chooses to partner with, for example, distributors, agents, etc.
The results of the ABAC Risk Assessment support CSL in a number of ways including the compliance procedures which are completed as part of the financial half- and full-year-end processes.
CSL engages with government officials and other stakeholders to contribute to the formulation of public policy in the countries in which we operate. We do this to ensure that public policy reflects the legitimate interests of the many stakeholders we serve and are responsible for, including patients, plasma donors, employees, investors and the local communities in which we have a presence.
Where contributions are permitted to political candidates or other political stakeholders by CSL or by the CSL Employees Political Action Committee, to which US employees may voluntarily contribute, they must be reasonably balanced among parties and candidates or representatives. Such contributions must be made in accordance with local laws and regulations and applicable authorisation levels.
We make decisions regarding how to undertake political contributions based on an understanding of the business relevance of the individual or political parties’ involvement in public policy issues that are important to CSL, taking into account stakeholder expectations and the ability to create shared value for patients and public health.