In terms of the Aspen Group Organisational Ethics & Legislative Compliance Policy, the Board is ultimately responsible for overseeing the implementation of organisational ethics and legislative compliance as contemplated in Principle 2 and Principle 13 of King IV, and the associated guidelines, respectively.
In addition to describing management’s responsibilities, the Policy establishes the Group Ethics & Compliance function (comprising a Group team and Regional Ethics & Compliance Officers) and describes the role, organisational status, authority, and scope of activities performed by the function.
The Policy also outlines the areas overseen by the Social & Ethics Committee, the Audit & Risk Committee, and the role of Internal Audit in providing periodic independent assurance on the effectiveness of the Ethics & Compliance Programme.
The Group Executive Committee, supported by the Group Ethics Committee, maintains oversight of transactions or relationships that could give rise to ethical, compliance or reputational concerns.
The Group Ethics Committee is also responsible for ensuring that allegations of fraud or related material breaches are appropriately investigated and that disciplinary or other corrective actions are applied fairly and consistently across the Group.
We promote a culture of openness and transparency throughout the Group and, as such, employees and other stakeholders such as our suppliers and service providers are encouraged to speak up when they have a reasonable belief or suspicion of unethical or unlawful conduct concerning Aspen’s business. We do not tolerate retaliation against anyone who reports ethical concerns in accordance with the Aspen Whistleblowing Policy. An independently monitored whistleblowing hotline – Deloitte’s Tip-Offs Anonymous Hotline – is available to all our employees and other stakeholders to report suspected fraud, bribery, human rights violations or other activities in breach of our Code of Conduct. Our Whistleblowing Policy provides guidance to prospective whistleblowers and details the protections available to them, including protection against retaliation. Training and awareness sessions are conducted periodically to promote the use of this facility for its intended purpose. Key customers, service providers and suppliers are periodically informed of the availability of this line. All reports from this hotline or from other whistleblowing sources received during the year are logged and, where appropriate, reported to the relevant managers timeously after consideration by the Group Ethics Committee. Disciplinary action is taken in instances where employees are found to have transgressed, with corrective actions implemented where necessary to improve controls and to prevent recurrence of the incident. All instances of misconduct, which may also constitute criminal conduct, are reported to local prosecution authorities as may be appropriate. Reports detailing the tip-offs received, how these tip-offs have been investigated and the corrective measures taken, are submitted to the Audit & Risk Committee and Social & Ethics Committee on a quarterly basis.
Our Group Conflict of Interests Policy prohibits all employees, officers and directors of Aspen from using their position within Aspen, or Aspen’s relationship with its customers, suppliers, contractors and other business partners for private gain, or to obtain benefits for themselves or their family members. Employees and directors are required to sign a Conflict-of-Interest Declaration upon commencement of their employment/appointment, and on an annual basis thereafter. Conflicting interests that are disclosed are reviewed by the Ethics Committee and are either disallowed or approved based on an agreed mitigation plan. Each business unit maintains a Conflicts of Interest Register, which is submitted to the Group Head: Ethics & Compliance on an annual basis.
Our Gifts & Hospitality Policy requires that where employees, officers and directors exchange gifts and hospitality with suppliers, service providers or customers, they must ensure that it is not intended or might be seen to influence business decisions, that there is a legitimate business interest for giving or accepting the gift or hospitality and that it remains once-off or irregular in nature. In addition, any prior approvals based on value thresholds must be strictly adhered to. Each Aspen business maintains a Gifts and Hospitality Register which is submitted to the Group Head: Ethics & Compliance on an annual basis. Employees perform Aspen’s Ethical Business Conduct training at the commencement of their employment with Aspen, and on an annual basis thereafter. The training addresses the standards of ethical business conduct set out in the Code and the mechanisms available to report concerns.
We periodically request our employees to participate in an anonymous Ethical Culture Survey to measure and understand our ethical culture and implement measures to address areas of concern.
Other policies that support our Code by enabling compliance with material laws affecting our business include;
Our Anti-bribery and Anti-corruption Policy prohibits the offering, providing, authorising, requesting or receiving of bribes. It also prohibits political donations or facilitation payments. Given the heightened risks associated with engaging third-party agents and intermediaries, the Policy also addresses the requirement for conducting risk-based due diligence on these parties and monitoring their activities throughout the commercial relationship. We do engage in policy debate (lobbying) on subjects of legitimate concern to our business, however, all officers and employees must, in doing so, comply with all applicable laws and regulations, and our Advocacy and Government Relations Policy. We do not provide charitable contributions, grants or other community investments to disguise a bribe, or to gain an improper business advantage. When we provide such support, we conduct risk-based due diligence on the recipient and monitor the use of the funds to ensure these are used for the purposes agreed upon. We only give and accept reasonable, appropriate, and lawful gifts and hospitality that are consistent with our Gifts and Hospitality Policy. We do not employ individuals in exchange for obtaining or retaining business.
Our Data Protection Policy sets out our commitment to complying with all applicable privacy laws. To manage our risk exposure and ensure compliance, we implement a range of controls and processes. These include privacy notices for our data subjects, personal data breach procedures, and procedures to allow data subjects to exercise their rights. Aspen also has a procedure for including appropriate data processing terms in the contracts it concludes with its data processors.
Our Competition Law Compliance Policy sets out our commitment to complying with applicable competition laws. To manage our competition risk exposure and ensure compliance, we implement a range of controls and processes. These include measures to ensure that we compete fairly in our engagements with customers, competitors and in situations where we hold a dominant position in the market.
Our Sanctions and Export Controls Policy sets out our commitment to complying with applicable international trade controls. To manage our sanctions risk exposure and ensure compliance, we implement a range of controls and processes. These include screening our counterparties using a risk-based approach to determine whether they are a sanctions target or otherwise attract sanctions risk, and assessing whether our products are controlled for purposes of export to certain end-users or destinations.
As a participant of the UN Global Compact, we are committed to upholding the principles of respecting and protecting internationally proclaimed human rights, as well as ensuring that we are not complicit in human rights abuses.
Our Human Rights Policy records our commitment to conducting our business in a way that respects the human rights of stakeholders across our value chain and the related procedures and governance structures in place to give effect to this commitment.
Aligned to the requirements of the UK Modern Slavery Act, the Australian Modern Slavery Act and equivalent legislation in the jurisdictions in which we operate, we report annually on the procedures and initiatives we have implemented to embed human rights commitments within our business and supply chain.
Our Policy on Product Promotion and Scientific Engagement sets the standards for ethical interactions with healthcare professionals as part of our promotional and non-promotional activities. Aspen’s relationships with healthcare professionals are intended to benefit patients and to enhance the practice of medicine. Interactions are focused on informing healthcare professionals about medicines, providing scientific and educational information, and supporting medical research, and education.
Our Advocacy and Government Relations Policy sets the standards for ethical engagement with other stakeholders in the healthcare community (government authorities, scientific societies, trade associations, experts, patient organisations and non-governmental organisations) on matters of public policy that affect patients, the pharmaceutical industry, and our business, in the countries in which we conduct business. The Policy also addresses the subject of employing certain former government officials. It requires an assessment of, and where necessary, implementation of a cooling-off period to maintain transparency, avoid conflicts of interest and maintain trust in public sector decision-making.
Information on the financial or other support Aspen provides within the healthcare community is outlined under the section on Corporate Social Investment.
Governance structures and procedures are in place for providing financial resources and in-kind support to external parties. These ensure that all external funding activities align with Aspen’s mission, values, and strategic goals, while promoting transparency, accountability, and ethical stewardship of resources aligned to accepted industry practices.
When conducting testing on animals we work with relevant government bodies, scientists, accredited laboratories and animal welfare groups.
