Oversight and Compliance

Global Social Responsibility Oversight

As capital is increasingly directed towards companies that seek to realize opportunities and create value by solving societal challenges while effectively managing inherent risks, we continue to further integrate GSR components into our strategic and operational efforts.

To support top-level commitment and visibility to GSR, Mylan’s Head of Global Sustainability reports to Mylan’s CEO. This function oversees the development and execution of Mylan’s goals on relevant GSR topics and philanthropy. It also complements the company’s approach to corporate governance.

Additionally, a multi-functional GSR Advisory Committee comprised of senior leaders convenes monthly and supports the integration of relevant GSR topics across the organization.

To ensure top-level commitment and accountability, Mylan’s Risk Oversight Committee, established by Mylan’s Board of Directors, oversees management’s efforts with respect to GSR.

Managing Enterprise Risk

In 2018, we enhanced our enterprise risk assessment, a key component of the company’s enterprise risk management (ERM) procedures that are used to identify and mitigate emerging and high risks. As we conducted our first comprehensive GSR priority assessment, we took the opportunity to align the processes, allowing for the GSR priority assessment to inform the enterprise risk assessment and ultimately the company’s risk profile.1

Another key component of our ERM program is Mylan’s Risk Oversight Committee. This committee was formed by our Board of Directors to support its supervision of the company’s enterprise risk management framework. Together with the Board’s Audit Committee and the Compliance Committee, it cohesively addresses the effectiveness of Mylan’s internal controls over financial reporting and the implementation of the company’s Corporate Compliance Program and Code of Business Conduct and Ethics.

To operationalize our Enterprise Risk Management (ERM) program, Mylan established a Risk Management Team (RMT) in 2018 to identify risks and opportunities and to evolve organizational readiness. It reports to Mylan’s Executive Governance Team and includes many of Mylan’s most senior leaders as well as Mylan’s Head of Global Sustainability and Head of Global Internal Audit.

As we expand into new geographies, safeguarding integrity in business conduct is key. Mylan has well-established procedures to identify, implement, mitigate and monitor risks as part of expanding our business. More specifically, risks associated with expansion into new geographies are an element of our ERM program.

1For more detailed information about the risks and uncertainties associated with our business activities see our Annual Report on form 10-K for the year ended Dec. 31, 2018

Upholding a Culture of Compliance

To ensure Mylan’s Corporate Compliance Program is effective and robust, we provide the adequate procedures and guidance to reinforce the idea that everyone at Mylan – and those acting on its behalf – are personally responsible and accountable for the company’s reputation and dedication to doing business with integrity.

Goal: Train at least 90% of Mylan’s applicable employees on the company’s Anti-Corruption Policy
Trained in 2018
Goal: Train at least 90% of employees on the Code of Business Conduct and Ethics
Trained in 2018
Goal: Train at least 90% of Mylan’s applicable employees on the company’s Fair Competition Policy
Trained in 2018

1For more detailed information about the risks and uncertainties associated with our business activities see our Annual Report on Form 10-K for the year ended Dec. 31, 2018

Fighting Corruption and Promoting Fair Competition

Our anti-corruption program is based on the elements of the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Resource Guide to the U.S. Foreign Corrupt Practices Act; the U.K. Ministry of Justice Bribery Act 2010 Guidance; and the Good Practice Guidance on Internal Controls, Ethics and Compliance from the Organisation for Economic Cooperation and Development (OECD).

Mylan’s Global Anti-Corruption Policy strictly forbids bribery and corruption in any form anywhere we do business. The policy defines bribery and corruption, including facilitation payments, which are strictly prohibited even where permitted under law. Mylan has monitoring and auditing procedures in place to identify and deter such payments. We reassess our anti-corruption program periodically and make updates as warranted. Our ERM program is closely tied to our work in this area.

Our anti-corruption program is based on the elements of the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Resource Guide to the U.S. Foreign Corrupt Practices Act, the U.K. Ministry of Justice Bribery Act 2010 Guidance, and Organisation for Economic Cooperation and Development’s Good Practice Guidance on Internal Controls, Ethics and Compliance.

Addressing Ethical Marketing and Promotion

Mylan employees often interact with members of the healthcare community as part of their efforts to educate on the appropriate use and efficacy of Mylan’s products. These interactions are important and fundamental to increase patient access but may bring elevated risk.

Mylan’s Standards for Interactions with Healthcare Professionals (HCPs) instruct employees on proper behavior when engaging with HCPs. The guidelines are grounded in Mylan’s companywide standards and take into consideration local laws and regulations. Compliance with the standards is mandatory for any member of Mylan’s workforce who interacts with HCPs.

Risk assessments and employee training are key components of each. We strive to comply with regulations and adhere to ethical standards set forth by Mylan and industry associations.

Respecting Human Rights

Mylan is committed to the 10 principles of the U.N. Global Compact and respects the International Bill of Human Rights and the Fundamental Conventions of the International Labour Organization.

Mylan’s global polices and associated procedures, employee and partner training and due diligence, are the foundation of our work to mitigate the risk of human rights violations.

Topics critical to protecting human rights such as:

  • freedom of association
  • legal compliance,
  • prohibition of trafficking of persons,
  • prohibition of forced and child labor,
  • handling of identity and immigration documents,
  • wages,
  • working hours,
  • safety in the workplace,
  • preventing harassment and
  • recruitment practices

are addressed through a variety of Mylan policies including our Code of Business Conduct and Ethics, Supplier Code of Conduct, Global Policy on Combating Trafficking in Persons and our companywide EHS program.