The Business Compliance & Integrity program is designed to prevent and detect misconduct and help the Company abide by the letter and spirit of the laws in all the countries in which West operates.
We require our employees to complete annual training on West’s Code of Conduct and other corporate policies on ethical business practices and have systems in place designed to detect violations of laws, regulations and company policies.
The Business Compliance & Integrity Department is dedicated to empowering employees to make better decisions and drive growth by doing the right things in the right way every day. This means each West team member knows, understands and acts in the best of interest of West which includes the patients who use our products, our customers and their fellow West team members across the globe. This requires each of us to act with integrity, honesty and transparency everyday. All West team members must uphold these values and principles to help ensure that West continues as a well-respected, ethical and lawful leader in the healthcare industry. Oversight
In 2022, West continued to reinforce its efforts to build and maintain a culture of integrity through its Business Compliance & Integrity program.
The West Business Compliance Committee (WBCC), chaired by the Chief Compliance & Privacy Officer and comprised of all members of West’s Leadership Team as well as the Head of Internal Audit, continued to provide strategic direction for our compliance activities and ensure regular reporting to the Audit Committee of our Board of Directors. The WBCC meets throughout the year to oversee the processes to ensure the company operates in a manner that complies with laws and regulations and reflects our high standards of integrity. On an annual basis, the full board of directors reviews the company's overall state of compliance, and the Audit Committee receives updates on compliance at each meeting.Written Standards
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 West’s Code of Conduct and focused on doing the right things in the right way, everyday. The Code of Conduct establishes the core principles that govern all West employees and provides direction for conducting business consistent with the company‘s values, policies and legal obligations. The Code of Conduct, which is available in multiple languages on WestPharma.com and West’s company intranet.
West has established & maintains policies and procedures designed to ensure compliance with the Code of Conduct, relevant laws, regulations and industry guidance in each of the countries in which West operates.
West also has a Business Partner Code of Conduct relevant for all suppliers currently working with West and for suppliers looking to provide products or services to West. Education and Training
West requires ongoing training and education of all employees on the Code of Conduct, West policies and procedures, and applicable legal requirements for specific roles. West conducts an annual Code of Conduct recertification training process, which requires team members to review and agree to the Company’s expectations related to their business-related conduct. West team members may also receive targeted training and education for their respective location or function.
In November 2022, West held its annual Compliance Week with a refreshed approach focused on Compliance & Cybersecurity to drive a strong commitment and ensuring every West team member is aware of the importance of Speaking Up and keeping West information and systems safe. Focusing on the theme of Recognition, Awareness and Reinforcement, the week featured a combination of live and online games to increase awareness of doing the right things the right way, every day. This year’s theme, “Awareness Recognition & Reinforcement,” underscored the importance that every West 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.Communication
West actively promotes open communication at all levels of the organization. West team members understand they have an obligation to Speak Up when they have questions or concerns about potential violations or unethical behavior. Throughout 2022, we continued to share frequent communications on the importance of speaking up and reminders on the non-retaliation policy and available reporting avenues.
Having a Speak Up Culture @ West means that:
- Everyone is strongly encouraged to raise questions and concerns whenever they witness ethical or legal misconduct, policy or procedural violations, safety or quality issues, etc.; and
- Everyone feels safe and empowered in raising their concerns; and
- Everyone trusts that their concerns will be taken seriously.
West offers several methods for West team members or business partners to raise questions or concerns:
- Your manager and/or shift supervisor;
- Any company manager;
- Any member of Human Resources or Quality;
- Any member of Business Compliance & Integrity department (firstname.lastname@example.org, in the US call 1-800-345-9800, Internationally call 1-610-594-2900);
- Any member of the Law department; or
- Integrity Helpline (www.west-helpline.com or 1-800-461-9330)
West team managers and leaders are expected to support and promote this open communication. The Integrity Helpline website also lists up-to-date local phone numbers for any country West operates and translation services are available. Reports to the Integrity Helpline may be made anonymously, except where limited by local privacy laws.Auditing and Monitoring
On an ongoing basis, West evaluates, monitors and audits business compliance with policies and procedures. In addition, the Business Compliance & Integrity department evaluates compliance risks and actively monitors mitigation steps. We report findings to top leaders, local management and the WBCC.Response to Potential Violations
West uses a clear and consistent process for investigating all reports of potential violations and addressing any substantiated violations via a cross-functional disciplinary review board to ensure timely response and actions. In addition, the Business Compliance & Integrity department in collaboration with HR and Legal review procedures, processes and business practices to identify changes needed to prevent further violations.Data Privacy & Protection
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.
Anti-corruption: Our anti-corruption compliance program is consistently implemented in all geographies in which we operate and includes partnership with the business to assess the appropriateness of interactions with third parties, with a goal of preventing corrupt business practices. See our Anti-Corruption Policy.