We are committed to doing business the right way, based on the highest standards of integrity.
Business Ethics
We are committed to doing business the right way, without exception, and we expect our associates to adhere to the highest standards of honesty and integrity. We designed our global ethics and compliance program to promote a culture of ethical behavior in accordance with the Compliance Program Guidance published by the Office of the Inspector General, US Department of Health and Human Services. Alcon’s framework of ethics governance covers standards of behavior, associate training, auditing, reporting, and disciplinary actions.
Our Code of Business Conduct defines our standards of conduct and the shared responsibility of all our associates and our Board of Directors to act ethically and responsibly.
The Lens, our global policy on professional practices, defines the requirements for associates interacting with healthcare professionals. The Lens emphasizes five ethical principles that apply to all Alcon interactions with healthcare professionals:
- We must put patients and consumers first
- We must act with clear and proper intent
- We must research for the right reasons
- We must engage appropriately
- We must fund and donate responsibly
We embed this core policy into each of our business operations around the world. We communicate these requirements to our associates through a multichannel approach that involves formal training on global and local perspectives, quick reference guides to assist with daily activities, and frequent reminders to keep these principles front of mind.
We are committed to communicating about our products and services responsibly and in a manner that is accurate, truthful, and appropriate for the intended context. We promote our products according to their approved use, and we design our policies and procedures, including The Lens, in accordance with requirements. We test compliance with our policies and procedures through our auditing and monitoring program on an annual basis.
We foster an environment where our associates can ask questions and raise concerns about unethical or inappropriate behavior in good faith, without fear of retaliation. We have processes to enable any associate to speak up at any time. An independent third party maintains Alcon’s Ethics Helpline, which provides 24/7 live and web-based support in 21 languages. All reported concerns are reviewed in a timely manner. For any instances of confirmed misconduct, we carry out appropriate corrective or disciplinary actions up to and including termination of employment.
Our Results
In the last five years, we have achieved a 98% or better completion rate for Code of Business Conduct Training. We have not incurred any monetary losses resulting from ethics in the five year period ending in 2019.
Responsible Procurement & Supply Chain
We expect our suppliers to meet Alcon’s standards in delivery, cost, innovation, and regulatory targets. In order to do so, we collect and track this data through business reviews and new business evaluations. We promote the societal and environmental values of the United Nations Global Compact to our suppliers and use our influence, where possible, to encourage their adoption. Our Third Party Code of Conduct (insert link) covers topics including labor rights, health and safety, environment, animal welfare, anti-bribery and fair competition, data privacy and information protection, conflict minerals, management systems, and trade sanctions and export controls. We provide a link to the Third Party Code of Conduct in our Global Master Service Agreement and in our electronic purchase orders. We require our third parties to comply with these standards and expect third parties to adopt, with their own suppliers, standards that broadly cover the same principles contained in our Third Party Code of Conduct.
Alcon maintains an ongoing risk mitigation project team to manage the risks in our supply chain of critical materials. This includes dual-sourcing most critical materials used in our production process and diversifying our supplier base. We seek to understand the origin of the materials that go into our products, and we have adopted a formal Conflict Minerals policy for our suppliers and we filed our first Conflict Minerals Report (insert link) as a standalone company last May, 2020. Lastly, we seek to build a strong Supplier Diversity Program by collaborating with best-in-class suppliers from diverse categories.
Our Results
Our annual spend with the largest direct material supplier to Alcon accounts for less than 4% of our total annual direct material expenditure. We track our spending on diverse suppliers to measure our impact and in 2019, Alcon spent 12% of our US supplier spend on qualified diverse suppliers.
Cybersecurity & Data Privacy
Many of our technological advancements enable exciting opportunities for data collection and analysis while improving customer experiences. However, these advancements also increase our responsibility to protect the personal information entrusted to us. In 2012, we began a multi-year software implementation project to standardize our digital processes, enhance data transparency, and integrate our information technology systems across our global operations. To do this, we made a significant investment in a new enterprise resource planning software platform. The consolidation of our enterprise-wide data and the rationalization of systems will enable Alcon to better protect information assets under our Cybersecurity and Information Management processes. We raise user awareness around risks from phishing, malware and best-practices in IT security and relevant data privacy training across all functions. Alcon’s security and compliance model is aligned with internationally recognized industry standards for security.
For more information, please visit Alcon’s Responsible Business Practices site.