Management of Societal Relations

Goals and performance

The practices and methods pursued by Orion as regards community relations, social and political relations, restrictions of competition and corruption are derived from the general principles of our Corporate Governance Manual, according to which the operations of the Orion Group are based on compliance with the valid laws and regulations issued therein as well as with ethically acceptable operating principles.

This is also the guiding principle in our Code of Conduct, which defines the Group’s ethical practices and commitment to complying with laws, ethically approved practices and respect for human rights. We expect all our staff in the Orion Group to comply with the Code of Conduct. All community relations are based on open and honest communication and interaction, in which both parties’ expectations are considered.

We accept that reasonable gifts are part of normal business culture within the framework of legislation and ethically acceptable practices. The principles that are included in the Code of Conduct and our Anti-Corruption Policy require that employees refuse to offer or take a bribe, or any comparable benefit. Orion has zero tolerance of all forms of bribery and corruption in its business operations. Identifying and assessing risks relating to corruption is part of the comprehensive overall Group Risk Management. Among other things, assessing bribery risks is also a standard part of the preparation of all collaboration agreements.

According to the donation policy of the Group, when deciding on donations it must be confirmed that each donation adheres to applicable laws and regulations and ethically acceptable operating practices.

Our principal channel for influencing political decision-making is via relevant industry associations.

Political parties or associations do not receive support from Orion. Even though we do not participate in the activities of political parties as a company, we respect the legal right of our employees to take part in political action, which is considered a private matter.

Orion adheres to the current competitive legislation. We are in favour of fair competition and promotion thereof, and we aim to ensure that the objectives of applicable competitive legislation are honoured in our operations. We strive to avoid any breaches of competitive legislation.

Legal and regulatory compliance is the cornerstone of all our operations. We expect every employee to be aware of the legislation and regulations that apply to their work. It is the responsibility of managers and supervisors to ensure that up-to-date regulations are available and that the employees are made familiar with them.

 

Procedures

The divisions and organisations that make up the Group are responsible for managing authority relations in the areas that fall under the scope of their operations and responsibilities.

When we want to inform political decision-makers and authorities of our opinion, for example when new laws or regulations are being drafted, we aim to do so via channels such as national and international industry organisations. We are a member of the European Federation of Pharmaceutical Industries Associations (EFPIA) and the Chemical Industry Federation of Finland, which is part of the Confederation of Finnish Industries EK. As the voice of business, regional and central chambers of commerce as well as the International Chamber of Commerce ICC are also relevant channels for us. Orion Diagnostica is a member of MedTech Europe and Sailab MedTech Finland.

When necessary, our managers can approach decision-makers directly. In terms of being able to voice our opinion we consider good and appropriate relations to be important, especially with local decision-makers in the regions where we have an operational presence, with the relevant regulatory authorities and, most importantly, with the national and municipal decision-makers and officials preparing decisions affecting the operating conditions of the healthcare industry.

In the relationships of our Pharmaceuticals business with Healthcare Professionals (HCPs) and Healthcare Organisations (HCOs), we follow the commonly agreed good practices provided in the European Federation of Pharmaceutical Industries and Associations (EFPIA) HCP/HCO Code. Collaboration between the pharmaceutical industry, HCPs and HCOs benefits patients. It is a relationship that has delivered numerous innovative medicines and changed the way many diseases impact patients’ lives. Our work together ranges from clinical research to sharing best clinical practice. We believe that being transparent and publishing the compensation paid to HCPs and HCOs for the time spent working with us every year builds an understanding of this collaboration and helps foster trust with stakeholders. We publish payments to HCPs and HCOs in our corporate and regional webpages. Orion Diagnostica, in collaboration with HCPs and HCOs, follows a similar type of ethical codes to MedTech Europe and Sailab MedTech Finland.

We want to improve data transparency and as a pharmaceutical company, it is natural for Orion to support the work of patient organisations. Here, we follow the established industry practices based on the EFPIA Patient Organisation (PO) code. A summary report of our collaboration with patient organisations is published annually in the Sustainability section of our corporate website and indicator is included in our reporting for economic performance.

Most of the annual donations made by the Orion Group for purposes of public interest are based on the decision made at the Annual General Meeting to donate part of the distributable assets of Orion Corporation to medical research and other purposes of public interest. The Board of Directors decides on the allocation of the donations. This indicator is also included in our reporting for economic performance.

 

Organisational responsibilities

At the Group level, the Executive Management Board is responsible for community relations.

 

Training and awareness

The practices and means related to community relations, social and political influencing, competitive legislation and anti-corruption are dealt with in both the company guidelines, the supervisor and expert training, induction of new employees and other training and information sessions where it is natural to discuss these issues. These issues are also addressed in the Group’s Code of Conduct.

The principles concerning anti-corruption are included in the Group’s Code of Conduct and in the Anti-Corruption Policy, which unambiguously instruct the employees of the Orion Group to refuse to offer or take a bribe or any comparable benefit. Employees are regularly and systematically educated and trained about the purpose and importance of these principles. In 2017, a new web based training was launched that is compulsory for selected staff in the Orion Group. The number of members of staff receiving anti-corruption training in 2017 was 2,808.

Identifying and assessing risks relating to corruption is part of the comprehensive overall Group Risk Management. Assessing bribery risks is also a standard part of preparing for all collaboration agreements, among other things.

In addition to the principle of legal and ethical compliance and anti-corruption specified in our Corporate Governance Manual and the Code of Conduct, we also have defined specific guidelines concerning competition law, which every Group employee is expected to adhere to. We arrange training related to competitive legislation and agreements for all employees who are involved in making agreements or other tasks, which may fall under the scope of competition law.

In addition, Group-wide guidelines apply for agreements and documents signed in the names of the Orion Group companies. These guidelines are in place to ensure that all agreements are made with sufficient legal expertise and in writing that agreements are approved at the appropriate decision-making level based on their scope, and that only authorised signatories of the companies can sign agreements.

Our operations are very highly regulated by legislation and special regulations. We arrange a lot of training for our staff in areas related to regulatory compliance by means of courses, information sessions and self-learning. The employees are also expected to be pro-active in acquainting themselves with the relevant provisions.

 

Complementary references

Human Resources Policy

Code of Conduct

Anti-Corruption Policy

Expectations towards suppliers

Our practices in approving suppliers