Ethics and 
Business Integrity

The CECO reports directly to the Executive Vice President and General Counsel while exercising independent judgement. The CECO has regular access to the Board of Directors, and the authority to effectuate change within the organization as necessary in order to exercise oversight and operation of UCB's Global Compliance Program.

UCB's Ethics and Business Integrity team works in partnership with designated Compliance Committees to provide oversight and support for compliance efforts and priorities. The Compliance Committees are comprised of senior leaders from cross-functional departments as well as key members from Ethics and Business Integrity.

Our comprehensive set of written standards, including UCB's Code of Conduct, policies and standard operating procedures, help guide our ethical decision-making and uphold compliance. Our employees, contractors, agents and other third parties conducting business on behalf of UCB are made aware of and trained on applicable written standards that pertain to their roles and responsibilities. They understand our expectations that these written standards be adhered to and the consequences of misconduct. They are further provided with an ethical decision-making framework to help uphold business integrity.

Our robust learning program includes ethics and business integrity training for new hires as well as ongoing training opportunities for employees with increasing responsibilities. All UCB employees are required to complete annual trainings on our Code of Conduct as well as the foundations of ethics and business integrity and compliance. Our ethical decision-making framework was also created to assist employees in upholding business integrity as they confront diverse and complex scenarios. Training and guidance materials as well as methods and modalities are routinely reviewed and adjusted to ensure they meet the needs of employees based on their roles and responsibilities. We also have education and training expectations for our business partners.

Our annual risk assessment enables UCB to more quickly identify, analyze, and address compliance risks as well as identify emerging risks and areas of concern. The risk assessment involves review of both external and internal risks. Some of the activities assessed include transfers of value to healthcare professionals, market access activities, and interactions with government officials. The results are reviewed, and a mitigation plan is developed. We use identified and prioritized risk areas to inform our auditing and monitoring activities throughout the year. We assess if our business activities are occurring as anticipated and in accordance with our written standards. The results of our auditing and monitoring activities inform business decisions and process improvements.

Our employees are encouraged to actively support one another to raise concerns or challenge ideas that could adversely impact the trust our stakeholders place in us, our value to patients, and/or how we do business. Our leaders, in particular, are expected to serve as role models in this regard. Speaking up is grounded in our culture of open feedback and transparent conversations. If an employee suspects potentially illegal, unethical or behavior that contradicts the standards found in our values and written standards, they are expected to say something to their manager. Additional channels for employees to report concerns or suspected misconduct are Ethics and Business Integrity, Talent Partner, or Legal Partners. In instances where an employee does not feel comfortable sharing a concern with their manager or the support functions listed above, UCB's Integrity Line is encouraged. The UCB Integrity Line is available to both employees and external third parties 24/7 via website or phone and is operated by an independent third party. Concerns can be reported anonymously. Employees can report concerns without fear of retaliation and will not be penalized for reporting, in good faith, what is believed to be a violation, even if it turns out that a violation did not occur. Retaliation is not tolerated in any form and is subject to discipline, up to and including termination. UCB's culture of ethics motivates us to take all reports seriously and to conduct a thorough review. More information on the UCB Integrity Line can be found here.

UCB enables our people to do the right thing by nurturing transparency and trust as well as clearly defined expectations. Any potential concerns or issues that are reported by employees or external third parties are treated as confidential and promptly investigated. UCB takes all reports seriously and has a process in place to handle each report on a case-by-case basis. The exact nature and level of thoroughness of the investigation varies depending on the circumstances. Once an investigation has concluded, corrective actions may be taken where our values and/or written standards were not upheld, including disciplinary action up to and including termination. Preventative measures may also be developed.

Due diligence and risk management of partners doing business around the world on behalf of UCB is key to upholding our core values and helping to ensure Ethics and Business Integrity is prioritized. Any interactions with third parties including agents, consultants, and distributors are analyzed to confirm there is a need to engage with the third party and, if so, that their activities performed on our behalf are done so in accordance with our values and written standards. This includes reviewing efforts a third party might take to conceal unethical or non-compliant behavior based on the activities UCB has requested they undertake. It also includes routine review of compensation standards for our industry within a geographic region as well as tracking third parties that do not align with our values and/or meet our written standards.