Promoting a culture of ethics and compliance
Ethical and compliant practices are a cornerstone of our work at Ipsen. We strive to integrate essential ethical concepts into our business, and to mobilise our teams around our vision of Ethics.
Our Code of Ethical Conduct is built on six main pillars: equity, transparency, dedication to health, integrity, compliance and speaking up.
These exacting standards guide all our work from research and development through to marketing, and ensure our patients remain our central focus.
Gender Pay Gap Report
Ipsen UK’s Gender Pay Gap Report includes our commitment to achieving a median pay gap of +/-2% across Ipsen UK by 2020.
Gender Pay Gap Report
Ipsen UK tax strategy and governance statement
FOR THE FINANCIAL YEAR ENDING 31 DECEMBER 2020
Ipsen UK comprises the UK subsidiary companies of the Ipsen SA group (“the Group”), based in France, namely Ipsen Biopharm Limited, Ipsen Limited, Ipsen Bioinnovation Limited, Ipsen Developments Limited and Sterix Limited. In making this tax strategy available, Ipsen UK is fulfilling its responsibilities under paragraph 16(2) of Schedule 19 FA2016 for the year ended 31 December 2020.
The tax affairs of Ipsen UK are managed in a manner that is consistent with the Group’s policy, to conduct business lawfully and ethically. The Ipsen SA group’s Code for Ethical conduct requires the maintenance of accurate and reliable financial records, and the tax approach aligns to that code.
How we manage tax risk
The tax affairs of Ipsen UK are managed in accordance with the Ipsen Group’s Internal control and Tax Management Policies. The UK Head of Tax has overall control and responsibility for the UK tax position and reports directly to the Group’s Vice President of Tax, who in turn reports directly to the Ipsen Group CFO.
Tax issues and risks are closely monitored at both UK level and Group level, and an annual report on the management of the Group’s tax affairs, including any UK issues arising, is prepared for the Group’s Audit Committee. In addition, external tax advisers provide specific tax advice and regular updates regarding upcoming changes to UK tax legislation to enable the UK companies to anticipate and plan for any potential impact on the tax risks.
Our attitude to tax planning
Ipsen UK’s approach is to pay the correct and fair amount of tax to minimise the risk of uncertainty or disputes. Where available, legitimate tax incentives (for example, R&D tax credits) or exemptions provided by HMRC are implemented to support the development of the UK businesses and any tax planning is based on commercial business activity. Transactions between group companies are on an arm’s-length basis and in accordance with OECD principles. Ipsen UK does not engage in artificial tax arrangements.
Our tax risks
Ipsen UK seeks to comply fully with the UK tax regulations and actively manages its affairs to minimise the risk of non-compliance by ensuring that tax returns and payments are made on time with proper disclosure made to the tax authorities. For areas of uncertainty, Ipsen UK will seek specific tax advice from external tax advisers or will seek clearance from HMRC, where necessary.
Our relationship with the tax authorities
Ipsen UK works with the support of its tax advisers to ensure that all compliance obligations are met and the correct amount of tax paid. Aligned to the Code for Ethical Conduct, we seek to operate an honest and transparent relationship with HMRC, providing the necessary disclosure required to allow HMRC to understand the operations and tax risk profile of Ipsen UK.
UK tax strategy
Statements under Section 172 of the Companies Act 2006
FOR IPSEN UK COMPANIES: IPSEN LIMITED (COMPANY NUMBER 06751069) AND IPSEN BIOPHARM LIMITED (COMPANY NUMBER 01653765)
The board of directors of the Company, both individually and collectively, believe they have acted in good faith, in a way that would most likely promote the success of the company for the benefit of its shareholders as a whole, whilst having regard to the stakeholders and matters set out in section 172(1)(a-f) of the Act for all decisions taken during the year ended 31 December 2019.
The board fulfils their duties partly through a governance framework that delegates day-to-day decision making to employees who make up committees of the company. Tasks were assigned to the UK & Ireland Sites Steering Committee, Leadership Team, Chairman of the Board, the Directors, Finance Director and Company Secretary as appropriate to their functions.
Our mission, strategy and consideration of the consequences of long-term sustainability of the business
As a dynamic and growing global specialty-driven biopharmaceutical company committed to improving people’s lives through innovative medicines in oncology, neuroscience and rare diseases. Our strong position in Specialty Care provides the scale, expertise and stability to make a sustainable difference for people in a quickly evolving healthcare environment.
1. Employee Engagement
The company has a strategic approach to identify, attract, hire and retain talented individuals to efficiently and effectively meet our ever growing and dynamic business needs. For our business to succeed, we need to manage our current performance, draw in and develop talent while ensuring we operate efficiently. We operate an annual performance objective setting and review process and ensure robust development plans are in place for all employees. Our Ways of Being and Code of Conduct empower employees to act in the best interests of the Company and its stakeholders.
The Company has a strategic approach to identify, attract, hire and retain talented individuals to efficiently and effectively meet our ever growing and dynamic business needs. For our business to succeed, we need to manage our people performance, develop and bring through talent while ensuring we operate efficiently.
We hold three cycle meetings each year with Company employees as well as regular town hall and “join the chat” events where employees have the opportunity to understand local and Group performance, engage with senior leaders and collaborate cross functionally.
Employee Engagement Survey
In 2019, all employees were invited to take part in an Employee Engagement Survey with the aim to benchmark results and offer site managers and management a clear understanding of the level of engagement with the Company’s strategy. An action plan is in development in response to the results and six-monthly pulse surveys will continue to monitor progress.
Family Fun Day
In August 2019, our Slough office hosted a well-attended family fun day where employees and their families were invited to site to enjoy the last day of summer. A host of attractions, games and refreshments were provided. The event helped to demonstrate the Company’s recognition of employees and the part their families play in ensuring the success of the business.
Paternity Leave Policy
In October 2019, the Company launched a new paternity leave policy effective from November 2019, allowing biological fathers, husbands or partners to take up to six weeks paid paternity leave for each child. The policy also covers same-sex parents, adoption and fostering.
The Company is committed to the highest ethical culture and compliance standards, consequently, the business expects employees to act according to the same standards. The Company has a whistleblowing policy encouraging employees to speak up and report behaviour that does not comply with the Company’s Code of Conduct, ethical principles and/or legal obligations. To this effect, a 24/7 whistleblowing hotline, independently managed by the Ethics & Compliance team was launched in July 2019.
To ensure that employees are aware of the importance of data protection, training modules were developed for all employees through online trainings and face-to-face trainings adapted to different functions of the business.
A dedicated Data Privacy Manager was recruited to support the Company in 2019 which has helped to increase levels of training for employees on data privacy matters and manage data privacy compliance in respect of employee and other stakeholder personal data.
Gender Pay Gap
In 2019, we published our Gender Pay Gap data for the entire UK organisation. Our results show a 1.5% median pay gap and mean pay gap of 14.8%. We took clear actions to improve the number of men and women receiving bonus within the organisation and as a result we are pleased to be able to report that over 90% of both male and female employees received a bonus in 2019.
The UK & Ireland Sites Steering Committee, an Executive Committee considered the financial and Human Resources implications of IR35 for 2020 onwards and the business impact of this legislation has been fully assessed and managed.
2. Stakeholder Engagement
Our ability to respond to stakeholders’ expectations is a measure of our credibility and sustainability.
The Company has a transparent and regular dialogue with its stakeholders including shareholders, payors, patients and healthcare professionals, suppliers, regulatory authorities and agencies, local communities and the media in order to provide reliable and factual information, to pursue a constructive dialogue, develop partnerships, support patient associations with the ultimate goal of providing differentiated and innovative solutions that improve patients’ lives.
Patients and Health Care Professionals
Board decisions during the year were driven by having patient needs at the centre of all discussions, maintaining the highest standards in terms of safety and quality to all our products, responsibly engaging with patients and patient organisations to ensure that we can properly understand their requirements and managing our supply chain to safeguard medicines supply.
The Company works with healthcare professionals, patients and patient organisations for the purpose of providing innovative solutions in compliance with our Code of Conduct, ethics & compliance policies, Association of British Pharmaceutical Industry (ABP1) Code and guidance from regulatory authorities and these topics continue to be areas of major focus for the board.
The Company operates a dedicated Medical Information service providing 24hrs service to respond to queries from healthcare professional.
Healthcare Professionals (HCPs) and Organisations (HCOs) work with us on a variety of activities ranging from clinical research to sharing best clinical practices and information. All interactions with HCPs and HCOs, patients and patient organisations are based on a legitimate, genuine need and business purpose. We disclose all interactions with HCPs, HCOs and patient organisations in accordance with ABPI transparency requirements.
The Company protects the personal data of our patients, healthcare professionals and other partners we interact with by being transparent about use of their data in all our activities. We recruited a dedicated UK & Ireland Data Privacy manager in 2019 to advise, implement and monitor compliance with Data Privacy regulations.
The board has established a dedicated quality management committee comprised of senior quality, regulatory, pharmacovigilance and supply chain managers to ensure that issues affecting the safety and quality of our medicines are properly managed and triaged to senior leadership as appropriate.
The board of directors understand the importance of continued relationship with shareholders, it is important to us that our shareholders understand that our strategy and objectives are aligned with the Ipsen global group (the “Group”) and there is a consistent and ongoing dialogue between the Company and the Group.
The aim of the board of directors of the Company is to ensure a good dialogue with its shareholders, Ipsen Developments Limited as well as other members of the Group to ensure continued financial performance and commercial success.
The board ensures appropriate governance is in place with our shareholders through regular functional business reviews, annual and quarterly budget reviews and board approvals for capital expenditure. We also implement appropriate controls to delegate authority from Group to Company management for contractual and financial matters.
Environment and the community
The Company is committed to protecting the environment and minimising our impact on it by making our activities safe and sustainable. believes firmly that responsible environment stewardship is essential to protect the planet and improve efficiency for a sustainable future. The Company is committed to ensuring environmental stewardship from the purchasing of raw materials to packaging and beyond, thereby ensuring the protection of the environment throughout the entire product lifecycle.
The Board of Directors had regard to all applicable regulatory requirements, Environment, Health & Safety policies standards and requirements while protecting the environment by preventing pollution.
In March 2019, 5 22kw dual charging points (providing x10 charging bays) were installed in the secure car park at the rear of our Slough office. The electric vehicle charging points not only benefit employees who have or/are considering electric car ownership, but also contribute to our corporate social responsibility plan and drive to be environmentally conscious.
By investing in the electric charging points, the Company have purposely enabled the initiative to have longevity as the number of charging bays outweighs the current number of electric vehicles owned by employees, which is increasing as a result. The future plan includes a rota system which will utilise the bays effectively and efficiently to charge the maximum number of vehicles throughout the working day.
In August 2019, the on-site restaurant at Slough went plastic free providing staff with reusable containers and changing any products that were sold in plastic bottles to products that have recyclable packaging.
The board has appointed a local Site Steering Committee for our Slough site to lead on the implementation of local projects which support the environment or local community.
In July 2019, the Company launched a Volunteering Policy to encourage employees to support community or charitable activities considered important to them thereby offering one day paid time off per calendar year to take part in volunteering activity that supports the Companies three pillars of Corporate Social Responsibility– Employees, Environment and Patients & Society. Though not exhaustive, the policy covers fundraising or any other activity that supports charities or activity aimed at improving the environment in the local community.
During 2019 members of the board and leadership team volunteered to deliver career support to local schools to demonstrate our support as a local employer in the community.
The board through its management team launched a new work experience programme in 2019, that offers students the chance to ‘follow the molecule’ across our three UK sites and gain insights into the full drug development process. Our 2019 intake comprised of 6 students across 4 schools (two schools in close proximity to the Wrexham site, and two schools within the Slough / London area). Students were tasked with a group project (to bring the newly discovered ‘molecule X’ to market in order to benefit patients), before a playback session at the end of the week. In support of this project students spent time with representatives from across the UK business including research and development, manufacturing, clinical operations, supply chain, commercial and ethics & compliance. When surveyed at the end of the programme, students felt they had gained a strong understanding of the pharmaceutical industry and energised about a career in healthcare. The Company also benefited from the students’ insights into their expectations of such a career which will inform future talent planning.
In October 2019, a team of 12 staff from Slough volunteered at the Thames Valley Adventure Playground. This not for profit organization provides children and adults with all types of special needs to enjoy the fun, freedom and friendship afforded by the opportunity to play and share experiences in a safe and stimulating environment. The staff assisted, by painting, decorating and repairing the playground as part of our volunteer programme.
The Company worked in close collaboration with a wide range of suppliers whose services and goods are critical to the performance of the Company and quality of its products. As part of the Ethics and Compliance programme, we operate an independently managed, risk-based approach to interactions with third party suppliers. This include due diligence, background checks and investigations into adverse media. Where risk is identified we look further into the supplier to establish what compliance practices they have adopted including their code of ethics, how they deal with concerns that are raised and human rights and labour laws. Where required, we provide training and education on our compliance and anti-corruption requirements. Due diligence also identifies sanctions against individuals associated with the supplier.
Our Business Partner Code of Conduct details our approach to avoid enforced labour, including child labour and to ensure respect of people. It also includes our commitment to the 10 principles of the UN Global Compact including those related to labour and human rights.
At a global level, there is the Company’s Third-party Compliance Programme, which aims to combat corruption and bribery. it. The Third-Party Due Diligence (3PDD), which assesses several hundreds of suppliers each year, was implemented with the following objectives:
- Identify and avoid transacting with any third party subjected to economic or trade sanctions; and
- Assess whether the third party can be reasonably expected to comply with anti-corruption laws after it is engaged.
The purchasing department have been working with a Company Rating Agency to conduct assessments and optimise sustainable positioning of its main suppliers. The Company also works with Ecovadis on the risk of improving the management of the 3PDD process.
The board regularly reviews the Company’s modern slavery statement to ensure responsible and ethical recruitment and sourcing throughout our Company.
All quality processes are documented in a formal Quality Management System (QMS) that insures full traceability on every batch of product. The QMS also assures that the processes are reproducible and allows teams to demonstrate this by means of the comprehensive internal audit. There is an established, documented, implemented and maintenance of effective QMS in accordance with the appropriate requirement of regulations, standards and directives.
The Board, through its management team, has worked closely with the Medicines Health and Regulatory Agency (MHRA) and the European Medicines Agency (EMA) in 2019 to secure local product licences for its portfolio of products to safeguard the supply of medicines to and from the UK following Brexit.
The management team also regularly attend MHRA symposia on regulatory, quality and pharmacovigilance topics as well as 1:1 clinics to enable senior stakeholder engagement and a two way dialogue on topics pertinent to our business.
Government and Payors
The board has an established public affairs function, the Head of which also heads the UK & Ireland Sites Steering Committee (which the board of directors are members of), ensuring that Government and Payor engagement is considered by the board and its committees.
The aim of this function is to ensure that the Company’s concerns are heard within government and government agencies and are aligned with the government’s agenda for industry. To further this aim, multiple two-way discussions have taken place in 2019 with senior stakeholders including the Chairman of NHS England, and Secretaries-of-State and Ministers within Departments for Health, Business, and Trade, as well as constituency MPs.
The board, through its management team, has worked closely with Government departments in 2019 to safeguard the supply of medicines to and from the UK following Brexit.
Section 172 Statement
UK Modern Slavery Act statement
Ipsen is committed to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the Ipsen business, or our supply chain.
This statement is made in accordance with section 54 of the Modern Slavery Act 2015, on behalf of the Ipsen companies operating and carrying on business within the UK (“Ipsen UK”). It sets out the steps that Ipsen UK has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Ipsen is a global specialty-driven biopharmaceutical group focused on innovation and Specialty Care. It develops and commercializes innovative medicines in three key therapeutic areas – Oncology, Neuroscience and Rare Diseases. At Ipsen the patient is at the heart of what we do. We continuously invest to innovate and deliver therapeutic solutions for the patient’s benefit. We also adhere to the highest ethical standards to ensure that our decisions are made in the best interests of patients.
Ipsen UK consists of the following Ipsen companies operating and carrying on business within the UK:
- Ipsen Limited
- Ipsen Biopharm Limited
- Ipsen Bioinnovation Limited
- Ipsen Developments Limited
- Sterix Limited
Ipsen UK is integrated into a global supply chain involved in the manufacturing of pharmaceutical products through a global network of manufacturing sites and distribution centres. This network includes the procurement of goods and services from many external suppliers, contractors and alliance partners.
Ipsen is committed to conducting business in an ethical way. We adhere to several internal policies and programmes to ensure that we are conducting business in an ethical and transparent manner. All UK and Ireland policies are available to our employees on the company intranet, these include:
Code of Ethical Conduct
- Our Code of Ethical Conduct and Ethics and Compliance Guiding Principles describe our commitment to treating people with respect and in accordance with the law. This code is detailed further We strive to maintain the highest standards of employee conduct and ethical behavior when operating abroad.
Business Partner Code of Conduct
- Our Business Partner Code of Conduct explains the way we behave as an organisation and how we expect our employees and suppliers to act. This code details our approach to avoid enforced labour including child labour, and to ensure respect for people.
- Our robust recruitment process, including conducting detailed checks on our employees to make sure they are eligible to work in the UK. This helps to safeguard against human trafficking or individuals being forced to work against their will.
- Our Whistleblowing Hotline allows employees to report any malpractice or violation of the Ethical Code of Conduct without fear of recrimination. We fully investigate any reports and take appropriate remedial action where required.
- Our anti-corruption programme includes training, education and an alerts system for raising concerns – which we assess and investigate as appropriate.
Employee Assistance Programme
- Our employee assistance programme operates through a third-party provider which allows employees and their families access to confidential advice on a range of topics.
- We have a range of employment policies including Dignity and Respect at Work, Equal Opportunities that explain how we will treat people with respect as well as provide a mechanism (grievance policy) to challenge inappropriate behavior or a breach of any of our policies. These policies are regularly reviewed and updated to make sure they continue to be fit for purpose and aligned to any legislative changes.
Ipsen’s Ethics and Compliance Programme
The objective of Ipsen’s Ethics & Compliance Programme is to ensure a culture of integrity, enabling Ipsen to conduct its global business with the highest ethical standards, in full compliance with all applicable laws, regulations and Ipsen’s Code of Conduct. Underlying Ipsen’s Ethics and Compliance Programme are our Ethics and Compliance Guiding principles:
- Patient focus: The underlying rationale for all interactions must be the ultimate contribution to the well-being and care of the patients.
- Integrity: All interactions must be conducted in a truthful and trustworthy manner with business integrity.
- Independence: All stakeholder’s must feel respect and independence to perform their official professional duties. Ipsen must not interact with external stakeholders when there is an actual, perceived or potential conflict of interest arising from such interaction which may unduly influence the stakeholder’s decision or conduct or create the perception of doing so. Ipsen must remain independent to conduct its global business.
- Legitimate intent: All interactions must have a legitimate intent aligned with the Ipsen vision to discover, develop and deliver innovative medicines that improve patient’s lives.
- Transparency: All interactions must be transparent with business integrity.
- Accountability: Ipsen employees must be accountable and accept responsibility for their actions and commit to perform all interactions in compliance with Ipsen ethical standards, internal procedural documents, all applicable laws, regulations and industry codes.
- Information Exchange: Information provided by Ipsen must be accurate, objective, balanced and appropriate to the context and the stakeholders. Ipsen does not partake in any deceptive practices.
Ipsen UK employees
As part of our Recruitment Policy we conduct background checks upon employment to comply with regulations on work permits, visas and the right to work in the UK legally. This also involves a screening process, background checks and confirmation of qualifications.
As part of the Ethics and Compliance Programme, we operate an independently managed, risk-based approach to interactions with third party suppliers. This includes due diligence, background checks and investigations into adverse media. Where risk is identified we look further into the supplier to establish what compliance practices they have adopted including their code of ethics, how they deal with concerns that are raised, and human rights and labour laws. Where required, we provide training and education on our compliance and anti-corruption requirements. Due diligence also identifies sanctions against individuals associated with the supplier.
In addition to the above, as part of our standard agreements with suppliers, we require confirmation that they will carry out services in full compliance with all applicable legislations, regulations and codes of practice.
Our Business Partner Code of Conduct details our approach to avoid enforced labour, including child labour, and to ensure respect for people. It also includes our commitment to the 10 principles of the UN Global Compact, including those related to labour and human rights.
As part of their employment conditions, all Ipsen UK employees must agree to uphold Ipsen’s Code of Ethical Conduct. Training is provided as part of on-boarding and throughout employment on topics relating to Ethics and Compliance, as well as applicable legislation.
We also review regularly and improve our Ethics and Compliance Programme to ensure it remains current with respect to significant risks, developments and trends.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Ipsen UK has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business, by our partners or in our supply chain.
Director and Company Secretary
On behalf of the Ipsen UK Board of Directors
11 June 2020
UK Modern Slavery Act
Audience: General public
Date of Preparation: November 2020