Operating Responsibly in the Marketplace
We act lawfully, honestly and fairly when competing in the market, and strive to fulfil our responsibilities to shareholders while facilitating access to our therapies for patients. CSL does not tolerate corrupt practices in any market.
We participate in the development of public policy relating to health and healthcare both directly and in partnership with industry associations and patient advocacy organisations. We are open about our public policy initiatives in the interest of transparency.
CSL is committed to providing accurate, balanced and useful information to healthcare professionals and governments to assist them in providing the best possible care to patients and to help improve public health. This is a critical part of our role as a supplier of highly specialised biopharmaceuticals. All promotional and educational materials relating to our products are formally developed in conjunction with, and reviewed and approved by, our medical departments to ensure accuracy and compliance with all relevant legislation and voluntary codes in the markets in which we operate.
Our sales and marketing practices and interactions with healthcare professionals, consumers and other customers are also governed by laws and regulations including voluntary codes to ensure the appropriateness of these interactions. High levels of training for all employees that interact with our customers ensures adherence to the regulations and codes, which are in turn, enforced through our business practice.
CSL supports fair competition and forbids practices that would in any way mislead consumers, contravene applicable trade practices or competition laws, or constitute other unfair practices.
We provide employees with the required training to ensure full compliance against local laws and regulations, and we set internal policies and procedures, such as CSL’s Code of Responsible Business Practice (CRBP), Anti-Bribery and Anti-Corruption and Securities Dealing. We develop customised online training modules to support our compliance training needs and deliver face-to-face training sessions, particularly for employees in contact with external stakeholders.
CSL recognises that the pricing of medicines is an important issue in the pharmaceutical sector, especially for patients, governments and providers. Pricing is one of a number of factors that can affect patient access in developed and developing markets. We seek to price our therapies fairly and competitively in all markets, and we work with governments, patient groups and other healthcare stakeholders to address access issues relevant to our therapy areas. In many countries prices for our therapies are negotiated directly with governments or other major payers based on demonstration of cost-effectiveness or through a competitive tender process.
In other countries, where our therapies are predominantly supplied via the private market, prices are established based on a number of factors including competitive market forces and applicable government controls.
It is important to recognise that the price a consumer pays for medicines in the private market is also affected by duties and tariffs imposed on imported medicines, as well as price mark-ups by intermediaries such as wholesalers and pharmacies and in some cases, an additional fee by the healthcare provider.
In all cases, we seek to ensure the prices of our medicines reflect their clinical value to patients, the community and government in terms of efficacy, safety and disease prevention, whilst balancing the high risks associated with R&D and the need for a fair return on investment.
Contributing to Public Policy
At CSL we believe we can make important contributions to public policy, on issues that directly impact our businesses and where we have particular expertise. Our public policy initiatives are focused largely in Australia, the US and Europe. More information on CSL’s public policy focus areas can be found in our annual corporate responsibility reports or via the regional links below.
Statement on Political Contributions requires that any donations supporting the work of party and political candidates or representatives be reasonably balanced among parties, candidates or representatives, and must be in accordance with applicable local laws and regulations. CSL Behring employees in the United States have formed a CSL Behring Employees Political Action Committee (PAC). This legal entity has its administrative support provided by CSL Behring, consistent with US federal law, but is managed by an employee PAC member board (it is not controlled or managed as part of CSL Behring and the company cannot contribute funds for distribution to political candidates).
CSL’s Code of Responsible Business Practice (CRBP) contains a clear policy statement that all our businesses and employees must not directly or indirectly offer, pay, solicit or accept payments, or give or receive personal rewards or inducements in exchange for making business decisions, and that our employees and directors must not accept gifts or entertainment where doing so might influence, or be perceived to influence, objective business judgment.
The Anti-Bribery and Anti-Corruption Policy builds on the current statement in the CRBP and supports the considerable amount of work being undertaken in many areas of CSL’s operations to ensure that CSL is acting with Integrity (one of our core values) at all times.
When we seek to establish a presence in new markets, either directly or via a third party, we conduct a thorough analysis of the usual business practices in that market so as to assess the level of risk relating to corruption. We undertake thorough background checks on candidate employees and agencies and establish a code of acceptable practice from the outset. We include corruption penalty clauses in commercial agreements and specify requirements for detailed reporting on commercial, financial and marketing activities within the respective market.
We also maintain regular communication with our offices and agents, conduct annual performance reviews and undertake site and customer visits to monitor the conduct of those representing CSL. CSL’s Audit and Risk Management Committee monitors the company’s risks relating to corruption through risk reports from CSL business units and via the internal audit function. We assess our overall risk relating to corruption to be low, but remain diligent in enforcing relevant polices, mandatory training and the ongoing assessment of risk in this area.
Responsible marketing of medicines
The responsible marketing of prescription medicines is vital to maintaining consumer trust in the pharmaceutical industry and to ensuring that patients receive the greatest benefits from pharmaceutical products and services. It is governed by strict government regulation and industry codes in all countries where we operate.
At CSL we recognise that our valued reputation and success as a trusted supplier of biopharmaceuticals relies on ensuring our therapies are trustworthy and honestly represented in our interactions with healthcare professionals, consumers and other customers.
We are committed to complying with all applicable local laws, regulations and accepted industry codes relating to the responsible marketing and promotion of prescription medicines. Policies, standard operating procedures and training programs are in place in all CSL business units to ensure regulatory compliance and good practice.
For countries in which we engage third parties to market our products, we include clauses in operational contracts that require our distributors to comply with all applicable laws, international best practice standards and the principles set out in CSL’s Code of Responsible Business Practice.
Promotional review committees operate in all CSL business units. They may comprise senior marketing, medical, regulatory and legal staff members who are responsible for ensuring that information to be disseminated about our medicines and therapy areas is balanced, supported by scientifically valid data and compliant with relevant laws and codes.