Code of Business Conduct and Internal Education
At West, we believe that Compliance is everyone’s responsibility. Team members in all functions and roles are responsible for adhering to our core values every day as they work together to improve patient lives. West’s Code of Business Conduct (“Code”), available in multiple languages on WestPharma.com and West’s company intranet, serves as a statement of our culture and sets forth the expectations for our global One West Team for their interactions with each other and our stakeholders.
The Code compels team members to report their concerns using any of several reporting avenues and prohibits retaliation for reports made in good faith. Those reporting choices include the team member’s manager or any other manager at the Company. Team members can seek help from Human Resources, the Compliance and Ethics Office or the Law Department. West also provides the option to report anonymously through its Integrity Helpline, toll free or online, available 24/7 from anywhere in the world in multiple languages.
West conducted its annual Code training and recertification process in 2020, which requires team members to undergo training on several topics covered in the Code and review and accept the Company’s expectations delineated in the Code related to ethical behavior. In 2020, our training completion and Code recertification rate was 99%, aligning with our typical high completion percentages.
In November 2020, West held its annual Compliance and Ethics Awareness Week, with the theme of “Compliance in Focus — Compliance Week 20/20.” West recognized that the COVID-19 pandemic brought monumental shifts to our team members’ lives, which understandably challenged the ability to maintain focus. Throughout Compliance Week, team members around the globe engaged in discussions on three areas particularly relevant in 2020 — Trade Compliance, Cybersecurity and Speaking Up. The pandemic led to stricter border controls in 2020 and new considerations for Trade Compliance. Meanwhile, Cybersecurity, which we address separately below, became even more crucial as organizations combatted COVID-19 related cyberattacks. Lastly, West wanted to reinforce the importance of Speaking Up, especially for many of our team members who were adjusting to working remotely. Our global sites hosted both virtual and in-person, socially distanced, executive and guest speaking events, games, trainings and small group discussions. Team member attendance at events presented during Compliance Week reached unprecedented numbers.
In the past year, West has expanded its Compliance and Ethics training opportunities to empower team members to engage on topics related to our culture of Compliance. We shared frequent communications on the importance of Speaking Up, reminders on the non-retaliation policy and available reporting avenues, and lessons learned on the benefits of Speaking Up. Specific resources and trainings were provided for people managers on promoting an open-door culture where communication, feedback, and discussion about any matter of importance is encouraged.
West takes its critical responsibility to secure the personal data of its customers, team members and other stakeholders very seriously. We have programs and processes in place to maintain adherence to all applicable data privacy regulations, including the European Union’s General Data Protection Regulation, the California Consumer Privacy Act of 2018 and many others throughout the world. The number of jurisdictions where data privacy laws have been or will be implemented is constantly increasing. Protecting personal data will continue to be a key initiative in the future, and West is expanding resources dedicated to its data privacy program and educating team members on protecting against cyber threats.
In 2020, West continued to reinforce its efforts to build and maintain a culture of integrity through its Compliance and Ethics Program governance. Our Executive Compliance Oversight Committee (ECOC), chaired by West’s Chief Compliance Officer and comprised of all members of West’s Leadership Team, continued to provide strategic direction for our Compliance activities and ensure regular reporting to the Audit Committee of our Board of Directors. With guidance from the ECOC, our business unit Compliance committees support our global Compliance structure and its corresponding policies and procedures to support our team members in acting ethically in accordance with West’s high standards.