Better Shareholder Health
Corruption erodes the trust in public institutions, compromises fair competition and is costly to societies in multiple ways. Corruption also stands in the way of access to medicine and good health, making fighting it and promoting fair competition important to our business and mission.
Mylan’s Global Anti-Corruption Policy establishes and communicates Mylan’s strict prohibition against bribery and corruption in any form anywhere we do business. This policy defines bribery and facilitation payments (also prohibited by Mylan) and highlights the individual responsibility of employees to avoid recognize, prevent and report bribery and corruption, and to comply with all applicable laws against them. Anti-corruption and anti-fraud management are part of Mylan’s enterprise risk assessment process. We conduct assessments to confirm that our business transactions comply with company policies and applicable laws and regulations around the world. We monitor business activities that have elevated risks – such as HCP interactions – through established internal processes and controls. Our procedures also cover some business partners.
Mylan’s Code of Business Conduct and Ethics
The Code outlines guiding principles on how we should conduct ourselves and informs our policies and standards, while remaining true to our values. It provides high-level guidance on critical areas of the company’s business operations including:
► Operational compliance;
► avoiding fraud and corruption;
► complying with fair competition, anti-trust and pricing requirements;
► awareness and compliance with corporate and securities laws; and
► engaging in fair employment practices.
All employees receive training in the Code of Business Conduct and Ethics annually.
Fighting Corruption Through Strong Management
In addition to general training on business ethics, we require and provide dedicated training on anti-corruption, fair competition and Mylan’s standards for interactions with HCPs for employees with relevant job responsibilities. Vendors that may interact with government officials on our behalf also receive anti-corruption training. We conduct assessments to confirm that our business transactions comply with company policies and applicable laws and regulations around the world. We monitor business activities that have elevated risks – such as HCP interactions – through established internal processes and controls. Relevant policies include:
- Mylan's Code of Business Conduct and Ethics;
- Supplier Code of Conduct;
- Global Anti-Corruption Policy;
- Global Fair Competition Policy;
- Global Policy Prohibiting Discrimination, Harassment and Retaliation; and
- Global Policy on Combating Trafficking in Persons.
Strong Processes for Reporting Compliance Concerns
Mylan encourages open communication and believes this is particularly important for upholding a culture of integrity. We have a strong framework through which concerns can be reported. Employees can report a suspected matter to their manager, Human Relations representative, local or regional compliance officer, Legal department or our OGC. They also can use Mylan’s Compliance Line.