Our performance

Our long-standing Key Performance Indicator (KPI) (confirmed breaches of external codes) continues to provide a benchmark against which to report our performance, but the different national and regulatory definitions of an external breach mean that interpreting the data at a global level is a challenge. In addition, a single confirmed breach can involve more than one person failing to meet the standards required, and there may also be failures to meet standards which are not ‘confirmed’ and so will not affect the KPI.

Over the last two years, we have been looking at additional ways of reporting our performance which would support increased transparency about our practices. Last year, we introduced a new performance measure: the number and type of disciplinary actions taken in relation to breaches of external or internal sales and marketing codes, including the number of dismissals. This information provides the broader context of our internal governance and reflects how seriously we take breaches of our policies. Building on this, we are now also providing information about the severity of the external breaches together with the total number of failures to meet AstraZeneca sales and marketing standards (excluding external breaches).

Our performance

During 2011, we continued to provide targeted training for our people to ensure expectations and accountabilities were clear and understood as well as where to get further advice and support if needed. We also ran a targeted training programme specifically addressing our anti-bribery and anti-corruption (ABAC) commitments for senior management teams.

We identified a total of 17 confirmed breaches of external sales and marketing regulations or codes globally in 2011 (11 in 2010). Excluding the confirmed external breaches, there were 1,275 instances of failure to comply with our Code of Conduct and global policies in our commercial organisation, including contract staff. In relation to all these breaches (and it is important to note that a single breach can involve more than one employee failing to meet the standards required), we removed 214 people from their role, formally warned 570 people, and provided further guidance or coaching on our policies for 971 people.

We believe that the increase in identified breaches is due in part to our enhanced management oversight of compliance and heightened awareness of policy requirements fostered by targeted training, alongside improved data capture mechanisms. However, we acknowledge that our numbers are likely to continue to vary as we reshape our business and geographic footprint.

Making sure we focus our compliance efforts appropriately is a top priority. A key part of this is our detailed assessment of the local and global impact of each our external breaches, using a consistent set of risk assessment criteria to establish the severity of the impact. The most serious breaches are raised with our AstraZeneca Board Audit Committee together with associated response plans, including actions for preventing re-occurrence. In 2011, 10 of the confirmed external breaches were brought before the Committee.

US Corporate Integrity Agreement reporting

In April 2010, AstraZeneca signed an agreement with the US Justice Department to settle an investigation relating to the sales and marketing of Seroquel IR. The requirements of the associated Corporate Integrity Agreement between AstraZeneca and the Office of the Inspector General of the US Department of Health and Human Services (OIG) include a number of active monitoring and self-reporting obligations that differ from self-reporting required by authorities in the rest of the world. To meet these obligations, AstraZeneca provides notices to the OIG describing the outcomes of particular investigations potentially relating to violations of certain laws, as well as a separate annual report to the OIG summarising monitoring and investigation outcomes relevant to Corporate Integrity Agreement requirements.