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Code of Business Conduct
At West, we believe that every team member is responsible for ensuring that our reputation remains strong, and for fostering a culture in which compliance with the West Code of Business Conduct (“Code”) and adherence to our core values drives our everyday business activities. The Code, which is 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 in 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, 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 recertification training process, which requires team members to review and agree to the Company’s expectations related to their business-related conduct. In 2021, our training completion and Code recertification rate was nearly 98%, which is consistent with prior years.
In November 2021, West held its annual Compliance and Ethics Awareness Week with a focus on cybersecurity, third-party management and ESG topics. This year’s theme, “Mission Possible,” underscored the importance that every team member is responsible for maintaining West’s strong culture of integrity, which helps us to make delivering on our mission of a healthier world, possible. We are intensifying our efforts regarding ESG issues and dedicating additional resources to respond to all of our stakeholders and improve the world which we all share.
Throughout the year, we continued to share frequent communications on the importance of “Speaking Up” and reminders on the non-retaliation policy and available reporting avenues. We held trainings for all people managers, led by an external trainer with the theme of “Managers Matter — 3 Ways to Strengthen a Culture of Integrity.” This training focused on building an open-door culture where communication, feedback, and personal discussions are encouraged.
West also has a Business Partner Code of Conduct in place, and in 2021 we launched a new third-party online training platform, helping to ensure third parties understand our expectations and hold them accountable to our own standards. This new training platform provided expanded reach and an improved user experience. Also, as noted above, one of the priorities identified going forward is a greater emphasis on a more responsible supply chain, which includes diversity, sustainability and compliance considerations.
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. Therefore, in 2021 West expanded its global team dedicated to supporting data privacy and educating team members on protecting against cyber threats. Personal data protection will continue to be a priority for West into the future.
High-Level Oversight & Authority
In 2021, 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. Our compliance team also works closely with our ESG steering committee to ensure alignment and prioritization of goals.