Compliance Reporting and Non-Retaliation

A culture of corporate compliance is best achieved in an environment that promotes open communication, including open and candid discussion of concerns about compliance with applicable laws, regulations and Amgen policy. All managers are responsible for creating and maintaining a work environment that encourages asking questions about legal and regulatory compliance and the reporting of concerns regarding business conduct.

It is Amgen’s policy to provide an effective process for Amgen staff or their representatives to express concerns or report potential violations in good faith regarding Amgen business conduct without retaliation or intimidation, in accordance with applicable laws and regulations, and to encourage the reporting of any such concerns. This policy sets forth information and resources for Amgen staff or their representatives to ask questions and report concerns regarding legal and regulatory compliance.

Asking Questions About Compliance Requirements

Amgen staff or their representatives are encouraged to ask questions about Amgen’s compliance policies, procedures and practices and are expected to do so (i.e., ask questions) if they are unsure as to whether an action, activity or decision is consistent with law, regulation, or Amgen policy. To ask compliance questions, Amgen staff or their representatives should consult (in no particular order):

• Manager
• HR Business Partner
• Ombudsperson: Amgen has established an Ombudsperson to provide Amgen staff or their representatives with additional opportunities to ask questions.
• Law Department
• Compliance Council Members: Each functional unit has at least one representative who sits on the Compliance Council and who is knowledgeable about compliance policies and procedures for the function’s activities.
• Chief Compliance Officer: Amgen staff or their representatives may ask questions via the Amgen Business Conduct Hotline. The Hotline can be reached from any worldwide location at (888) 376-5574 any time of the day or night.

Appropriate Matters for Reporting

Appropriate matters for reporting include good-faith concerns regarding compliance issues or misconduct, such as:

• Violations of law or regulation (whether in the United States or elsewhere);
• Violations of Amgen policy and standards of business conduct;
• Violations of policies regarding financial disclosures, accounting, accounting controls or auditing matters; and
• Any other serious wrongdoing within Amgen, including but not limited to, conduct that is inconsistent with the Amgen Values.

Prohibition Against Retaliation

In accordance with applicable laws and regulations, Amgen policy prohibits any form of retaliation or intimidation against Amgen staff for reporting a compliance concern in good faith or for good-faith participation in any investigation or other proceeding related to such a report, even if Amgen ultimately concludes that there was no violation. This includes reports made through the Business Conduct Hotline, or those made through any other appropriate means.

Amgen staff members who engage in retaliation or intimidation in violation of this Policy will be subject to disciplinary action, up to and including termination, to the extent permitted by local laws. Any person who retaliates against another person for reporting actual or potential violations of law or regulation also may be subject to criminal and civil liability under U.S. federal and state laws and the laws of other countries.

Cooperating in Investigations

Amgen staff or their representatives are required to cooperate with internal investigations undertaken by Amgen.

In particular, among other things, Amgen staff are required to make themselves available to internal investigators immediately upon request, be fully forthcoming and truthful with investigators, and provide complete and accurate information.

Download the complete policy (PDF)