At BeiGene, we believe that cancer has no borders and neither do we. We support healthcare industry efforts and government policies that advance science, enhance medical innovation and ensure treatment affordability for patients around the world. We endeavor to earn the trust of our stakeholders by putting patients at the forefront, conducting business responsibly and being open and transparent. We adopt industry leading standards and partner with organizations who share our mission to build the first next-generation biopharmaceutical company — one that expands the highest quality therapies to more people — through courage, persistent innovation, and by challenging the status quo. We sponsor programs and participate in activities that support the scientific community, patients and caregivers, advocacy organizations, underserved communities and healthcare professionals globally.
We are committed to conducting our business ethically, legally, and with the utmost integrity.
To foster compliance with the laws, industry guidelines, and our own standards applicable to the development, manufacturing, marketing, and sale of our medicines, we have established a comprehensive compliance program. This program is structured to reflect the legal and regulatory requirements, industry guidance and best practices in the countries where we operate, such as those recommended by U.S. Department of Health and Human Services Office of Inspector General’s “Compliance Program Guidance for Pharmaceutical Manufacturers” (OIG Guidance).
Our compliance program, which is codified in the company’s Code of Conduct, is designed to (1) prevent, detect, and remediate violations of laws, rules, regulations, as well as our internal policies and procedures, and (2) promote a culture of the highest ethics and integrity within the organization. We have tailored our compliance program to fit the unique environment and risks of our company. Our Chief Compliance Officer has primary responsibility for developing, operating, and maintaining the effectiveness of the compliance program, and provides periodic reports to senior company leadership and our board of directors.
As the OIG Guidance recognizes, however, the implementation of a compliance program cannot guarantee the elimination of improper employee conduct. As such, we continually seek to improve our compliance program and encourage open lines of communication with internal and external stakeholders. Accordingly, we maintain a global helpline and web portal to report suspected violations of company policies, laws, or ethical concerns. Reports can be made anonymously and without fear of retribution 24 hours a day, seven days a week. All allegations or reports are reviewed, and where appropriate, investigated so that appropriate corrective action can be taken when warranted.
Our compliance program is designed to meet our evolving needs.
As part of our commitment to corporate compliance, we declare that, to the best of our knowledge, and based on a good faith understanding of the statutory requirements of California Health and Safety Code § 119400 and 119402, we have developed a global compliance program for our commercial operations as required by the Code. To the best of our knowledge, as of November 1 of the most recently completed year, we believe that the company is in compliance with its comprehensive compliance program and its good faith understanding of the requirements of California Health and Safety Code § 119400 and 119402.
We also have established a total annual dollar limit on items of value (including meals) that the company may provide to California Healthcare Providers (HCPs) in accordance with California Health & Safety Code § 119400 and 119402. Our established annual aggregate limit for each California HCP is $2,500. This annual limit may be revised by the company from time to time. Per California Health and Safety Code § 119400 and 119402, the annual aggregate limit does not apply to drug samples provided to HCPs that are intended for free distribution to patients, or to payments for legitimate professional services provided by an HCP.
For questions about our comprehensive compliance program or to obtain a copy of this declaration, please contact email@example.com.
We are committed to fostering an environment of open communication that encourages employees to ask questions about and suggest improvements to the Code of Conduct and company policies and procedures, or to raise concerns about suspected improper business practices. Our employees understand they have an obligation to speak up when they have questions or concerns about potential violations, unethical behavior, or any other alleged transgressions of our Code of Conduct and company policies.
Employees are encouraged to ask questions about compliance issues or make reports of potentially problematic conduct to their managers. Employees can report concerns to leadership, as well as the departments of Human Resources, and Legal and Compliance. We maintain a helpline available 24 hours a day, seven days a week, 365 days a year for employees and the public globally, subject to local law, online at BeiGene Ethics Point. Our helpline is administered by an independent outside contractor whose employees are trained to handle such reports.
We expressly prohibit retaliation or retribution against any employee for making any good faith report of suspected misconduct or improper behavior.
BeiGene takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly, and with integrity in all our business dealings and relationships. Each year, our employees sign our Anti-Bribery and Corruption Policy. Additionally, the Audit Committee of our Board of Directors receives quarterly reports on anti-corruption and significant compliance program activities.