Conducting Business with Integrity
At Gilead, we're committed to adhering to the highest legal and ethical standards. We operate in a complex global environment where our reputation is at the center of our success and foundational to our ability to continue our legacy of innovation. Our culture of ethical conduct enables scientific discovery, advances health equity and helps deliver innovative therapies for people with life-threatening diseases.
Our Culture of Ethics and Compliance
Our ethics and compliance program is central to our ability to ensure we're conducting business in the right way and promoting a culture based on integrity. We provide the tools and resources to support responsible decision making and know that every action taken by individual employees defines our culture.
As a values-based organization, our culture makes a positive impact internally and externally by integrating ethics and compliance principles into our day-to-day work and processes. An effective ethics and compliance program is essential to mitigating risk, yet it is also critical for building trust with patients, healthcare providers, other stakeholders and communities we serve. In addition, our program increases employee satisfaction, productivity and retention and helps attract talented prospective employees.
Six interrelated elements, described below, bring our compliance program — and our ethical culture — to life.
Leading by Example
We hold our leaders at all levels accountable to consistently demonstrate ethical conduct and to model behavior and provide inspiration for their teams to do the same. Ensuring our leaders lead by example allows us to similarly ensure each employee adheres to and is held accountable to all Gilead standards.
Our ethics and compliance program is built on a system of comprehensive policies and procedures, which every employee has the responsibility to be knowledgeable about and comply with.
Code of EthicsNew employees receive ethics and compliance training as part of their onboarding process, including training focused on the Code of Ethics and business conduct policies and procedures. In addition, to ensure adherence to standards, all employees take part in ongoing training programs. Employees are empowered with a variety of tools and information to promote responsible decision making and clear communication. Our approach to training is to make it transformative by continually evolving learning methods and modalities to increase accessibility, impact, engagement and relevancy.
A Safe Space to Speak Up
We believe a strong culture of ethics starts with open communication. We encourage everyone to speak up if they see or suspect any violations of our Code of Ethics, policies, or applicable laws and regulations. This includes unethical behavior or questionable business practices.
We're committed to providing a safe and confidential environment for raising concerns. We offer numerous reporting channels, including the Ethics Hotline, the Office of Ethics & Compliance, human resources, legal teams, and directly to all people leaders or the Chief Ethics & Compliance Officer.
Investigations with Integrity
We're committed to investigating all reports of potential violations of the Gilead Code of Ethics, Gilead policies, and applicable laws, regulations and industry codes, as well as any unethical behavior or business practice. We take all reports seriously and conduct thorough and prompt inquiries.
We also understand the importance of how we respond to an issue or concern, by analyzing the root cause when an issue is substantiated, implementing effective corrective action(s) when appropriate and fostering transparency. Additionally, we have a process for referring serious matters to an internal remedial action committee for review and response.
We routinely assess the risk of operations, including both corporate and affiliate level activities that include, among other risks, interactions with and/or payments to healthcare professionals, government officials, healthcare organizations, patients and patient organizations.
Through the assessment of risk areas, we validate the effectiveness of our policies, procedures and controls. Additionally, we use diverse risk-based monitoring tools and data analytics techniques to proactively detect anomalies and we collaborate with the relevant risk owners to pinpoint the root causes and recommend corrective action to mitigate risk where necessary.
We are committed to high standards of ethics and compliance with various anti-bribery and anti-corruption laws, including the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act, and the anti-corruption laws of other countries where Gilead and its third-party representatives do business. We only engage third parties capable of upholding the highest standards of ethics and integrity, including those detailed in our Anti-Bribery and Anti-Corruption Policy.
We conduct business in an ethical and compliant way because it's the right thing for patients, partners and the entire organization.
Robert Ladd
Senior Vice President,
Chief Ethics and Compliance Officer
Ethics Hotline
The Gilead Ethics Hotline is a confidential telephone and web reporting system hosted by an independent third party. It's accessible to everyone around the world, and it's available 24 hours a day, every day of the year. The phone and web-based reporting systems are available in multiple languages and reporting may be made anonymously where permitted by local law.
We're committed to fostering a safe environment where employees feel empowered to report concerns without fear of retaliation. We prohibit any form of intimidation or retaliation against individuals who file reports in good faith. Reports are handled in accordance with our Complaint Procedure and Non-Retaliation Policy and Internal Investigations and Disciplinary Policy.
Responsibility
We're dedicated to building a healthier world for all people. We bring this to life through our internal policies and culture as well as through our external partnerships and efforts in communities around the world.
Grow With Us
With more than 18,000 employees spanning across 40+ countries on six continents, Gilead has a global workforce dedicated to creating a better, healthier world for everyone.
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