Our performance

During 2012, we continued to provide training for employees on our global standards that govern the way that we conduct our business around the world. We have comprehensive processes in place for monitoring compliance with our Code of Conduct and global policies, including dedicated compliance professionals who support our line managers locally in monitoring their staff activities. We also have a network of nominated signatories who review our promotional materials against all applicable requirements. Additionally in 2012, audit professionals have conducted compliance audits of a selection of our marketing companies.

We identified a total of 10 confirmed breaches of external sales and marketing regulations or codes globally in 2012 and there were 1,932 instances of failure to comply with AstraZeneca’s Code of Conduct and global policies in our commercial organisation, including contract staff. The majority of these were minor. We believe that the movement in both numbers reflects our enhanced management oversight and compliance monitoring.

In relation to these breaches (and it is important to note that a single breach can involve more than one person failing to meet the standards required), we removed 188 people from their role, formally warned 685 people, and provided further guidance or coaching on our policies for 1,808 people. The most serious breaches are raised with our AstraZeneca Board Audit Committee together with associated response plans, including actions for preventing re-occurrence. In 2012, 3 of the 10 confirmed external breaches were brought before the Committee.

During 2012, we reviewed and revised our Global Policy on External Interactions (now Global Policy on Ethical Interactions), launched in April 2011, to take account of feedback from our employees, as well as some external stakeholders, about various aspects of the policy. Among other things, these insights helped us to understand that our approach of providing only modest ground transportation support for HCP travel to Company-sponsored events was impacting our ability to share the information about our medicines that helps HCPs to make informed prescribing decisions. We have therefore adapted our Policy to allow for greater support to bring doctors together, in limited circumstances, to facilitate high quality medical education and scientific exchange. Similarly, we have determined that we can support scientific discourse by sponsoring a limited number of doctors to attend international congresses, also in limited circumstances and with appropriate controls. We also took the opportunity to improve clarity in some existing aspects of the Policy to make sure that our employees fully understand the global requirements and how these should be put into practice at a local level. We are confident that our Policy, backed by internal training and the strong controls and safeguards we have in place, will continue to ensure that we deliver on our commitment to consistently high standards of sales and marketing practice worldwide.

US Corporate Integrity Agreement reporting

In April 2010, AstraZeneca signed an agreement with the US Department of Justice 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.