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
Find all the most recent Gender Pay Gap Reports for all of Ipsen UK here.
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 2020.
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 Teams, 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.
EMPLOYEE AND STAKEHOLDER ENGAGEMENT
2. EMPLOYEE ENGAGMENT
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 and develop our internal talent whilst also attracting and developing external talent to ensure we have the appropriate skills to deliver on our business objectives. Our Ipsen Way of Being and Code of Conduct empower employees to act in the best interests of the Company and its stakeholders.
We operate an annual objective setting process, annual talent reviews and an annual year end performance review process. We also ensure each employee has a robust development plan in place to ensure ongoing personal and professional development.
We hold three cycle meetings each year with Company employees as well as regular town hall and “join the chat” events where employees had the opportunity to understand local and Group performance, engage with senior leaders and collaborate cross functionally.
EMPLOYEE ENGAGMENT SURVEY
In 2020, 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 now underway in response to the results and six-monthly pulse surveys will continue to monitor progress.
GREAT PLACE TO WORK
All sites entered the GPTW assessment for 2020 to assess levels of employee engagement against other accredited Great Workplaces and to build a greater understanding of our culture at Ipsen. Wrexham and Milton Park were certified as Great Places to Work in 2020. This is to drive and sustain employee engagement. This assessment also offers external recognition and enhanced branding.
Ipsen operates a COVID safe environment at all our sites. We comply with regulations, but also protect our staff so far as reasonably practicable to prevent exposure to COVID. In order to support colleagues throughout the pandemic Ipsen offered online resources such as mind gym webinars, virtual yoga, meditation, employee assistant programme and doctor at hand. All employees were encouraged to take time out and book annual leave. Employees were encouraged to have shorter calls and breaks in between the calls. Ipsen also promoted keeping fit through the Ipsen in Motion programme and the United Heroes App. Ipsen offered flexible working hours to accommodate domestic requirements.
MENTAL HEALTH AND WELLBEING
In 2020, 26 Mental Health Ambassadors qualified. There has been an increase of enhanced Mental Health & wellbeing support via private healthcare to 28 days. All employees were given a world kindness and mental health care package. All sites received Covid-19 weekly email campaign during the lockdown to include wellbeing support and resources. To support Stress Awareness week, Mental Health Advocates conducted a wild wellness walks and Online Mindfulness and Meditation sessions.
LEARNING & DEVELOPMENT
Ipsen fosters a culture of learning and development, through our corporate values (“We Learn and Share Everyday”) and by implementing the 70:20:10 model of development: each employee is encouraged to have an annual Development discussion and plan with the manager, which is then tracked in the iPeople application. During 2020, there was a need to generate new projects to enable business continuity, which also provided opportunities for on the job development (70%). We were also able to provide coaching, feedback and 1:1 mentoring (20%) . of note, we invested in a broad range of training sessions (10%), which covered topics such as product training, remote customer engagement, Mentoring Retreats, Insights Discovery profiling and workshops focused on creating high performing teams. At a division and country level, succession plan and talent management discussions are held throughout the organisation to maximise development and internal mobility.
PARENTAL LEAVE POLICY
In 2020 we introduced an enhanced parental bereavement leave policy. In Q1 2021, we will be reviewing and updating all our parental leave policies to make sure they fully support the inclusive culture we are building at Ipsen.
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 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.
GENDER PAY GAP
In 2020 we have reviewed our internal pay equity position, based upon our market positioning and pay structure and will continue to monitor our position for 2021. Ipsen was pleased that in 2019, the data for entire UK organisation sat within our bold ambition of achieving a median gap to +/-2%. However, were disappointed to have increased the gap in 2020. Ipsen is aware of the issues that caused the increase and are committed to bringing the gap closer to the ambition in the coming years. Ipsen is very pleased that our dedication to ensure consistency in bonus schemes has led to a -1.9% median bonus gender pay gap and that over 95% of both male and female employees received a bonus in 2020.
DIVERSITY AND INCLUSION
A new interview skill and hiring Training was deployed by our Talent Acquisition team. This training has specific modules focused on avoiding unconscious bias and champions diversity and inclusion in our Talent Acquisition process.
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.
3. 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
Ipsen maintained 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 manage our supply chain to safeguard medicine supply.
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.
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. Our Wrexham manufacturing and development site are the pilot site for Ipsen’s new ‘Energy Strategy’ committing to driving down our totals companies’ energy consumption/absolute carbon by 30% by 2025 based on 2019 as a baseline year. Sustainable building and infrastructure are built into all new and existing projects ensuring that we consider our impacts on the environment across the life of our assets. In 2020 the world environment day “one small change” Biodiversity competition launched to encourage all employees to make a small change to help the environment. UK & Ireland employees were given an opportunity to take part in run for cancer research UK to raise money for the charity. Also, Global patient centricity events for Fibrodysplasia Ossificans Progressiva, Dystonia Awareness, Cerebral Palsy, Liver Cancer Awareness Month, World Kindness Day took place.
All of Wrexham’s electricity was supplied as green energy from sustainable sources, lowering our overall carbon footprint. The replacement of LED/sodium light fittings in warehouses, offices and external lighting upgrades, with the addition of motion sensors; solar panels were fitted to our newly built B1 office and packing line building; a system of purchasing and replacement of equipment for more energy efficient options were introduced; and boiler burners were replaced feeding our manufacturing facility. In addition, an energy campaign was begun highlighting the importance of reducing our usage of both gas and electricity across site(Wrexham), which included the roll out of sub-metering across site.
Lastly, Employees participated in raising funds for TOAD Hand sanitizer for Covid-19 vulnerable care homes in Oxfordshire, The Footsteps Foundation by walking or running 10,000 footsteps and for SSNAP John Radcliffe, Oxfordshire in the 39 Lockdown challenge.
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.
BUSINESS ETHICS & ANTI-CORRUPTION
The Company is working closely with the Ipsen Group on the ISMAC (Integrated Anti-Corruption Management System) project, which is focusing on ensuring the Company’s business ethics & anti-corruption programs are robust, efficient and under constant review. The Company, as a subsidiary of a French parent, is readying for potential inspection from the French anti-corruption agency AFA relating to the Sapin 2 law. The Company will also aim to achieve ISO 37001 certification to demonstrate the Company’s willingness to fight corruption.
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. Subject to periodic inspections by regulatory bodies with which we fully cooperate.
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.
On behalf of the board
2nd August 2021
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 committed to discovering new solutions for targeted debilitating diseases and improving quality of life for patients. 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 key Ethics and Compliance Principles describe our commitment to treating people with respect and in accordance with the law.
Business Partner Code of Conduct
- This code explains the way we behave as an organisation and how we expect our employees and suppliers to act. Our Business Partner Code of Conduct details our approach to avoid enforced labour including child labour, and to ensure respect for people.
- We operate a 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. Every HR professional at Ipsen has access to “HR Principles” document, which provides governance on all HR activities and guidance on our HR operating values. It is also part of the onboarding for any newcomers to the HR Community.
- 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.
- We have an anti-corruption programme, including training and education and an alerts system for raising concerns – which we assess and investigate as appropriate.
Employee Assistance Programme
- We operate an employee assistance programme through a third-party provider which allows employees, and their families access to confidential advice on a range of topics.
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.
We have a risk-based approach to our third parties. This is managed independently by the Ethics and Compliance Programme, which includes due diligence, background checks, investigations into adverse media and where risk is identified we look further into the supplier to establish what compliance practices they have adopted including how they deal with concerns that are raised, human rights and labour law and a code of ethics. 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.
On behalf of the Ipsen UK Board of Directors
10 April 2021
UK Modern Slavery Act