Amgen’s Culture of Compliance
Amgen is an innovative, science-based company dedicated to helping people fight serious illness – and we are committed to living the Amgen Values. Our values form a deeply held belief system that guides our behavior, helps us make the right decisions and builds the framework for our daily interactions with each other. We value people, integrity and results. This combination is essential in accomplishing our mission, which is to serve patients.
As Bob Bradway, our chairman and chief executive officer, reminds us, conducting ourselves in principled ways is core to our mission. There are no shortcuts. The Worldwide Compliance & Business Ethics Program enables Amgen's success by diligently partnering with the business to create effective solutions within the framework of regulatory requirements in order to provide clear and practical rules and guidelines.
Through the Worldwide Compliance & Business Ethics Program, Amgen's leadership empowers managers and staff to conduct business ethically by providing resources such as the Code of Conduct, which directs staff to policies, procedures, training and education, web sites, the Business Conduct Hotline, and guidance from managers and dedicated compliance professionals. However, with empowerment comes responsibility; Amgen's leadership holds managers and staff accountable for ethical business conduct by enforcing standards through internal monitoring, investigating and auditing, responding promptly to detected problems, undertaking corrective actions and applying disciplinary measures where appropriate.
The Worldwide Compliance & Business Ethics Program operates at the functional and corporate levels to continually integrate compliance into Amgen's business and culture. The Compliance Committee, chaired by Amgen's chairman and chief executive officer and comprised of Amgen's Operating Team, ensures Amgen's steadfast culture of compliance and business ethics are the foundation of the company's strategy, goals and objectives. The Operating Team members partner with compliance professionals within their organizations who have day-to-day responsibility for ensuring the unique compliance risks and requirements within their areas are addressed. These professionals also promote cross-functional alignment of compliance activities through their membership on the Compliance Council, which is chaired by Amgen's Chief Compliance Officer. The Chief Compliance Officer assures the effectiveness of the Worldwide Compliance & Business Ethics Program to the Corporate Responsibility and Compliance Committee of the Board of Directors (CRCC).
Corporate Responsibility and Compliance Committee of the Board of Directors (CRCC)
The Corporate Responsibility and Compliance Committee of the Board of Directors (CRCC) has ultimate oversight for Amgen's Worldwide Compliance & Business Ethics Program. The Committee periodically assesses management's implementation of, and ongoing improvement to, the program elements, including its systems and processes, mechanisms for employees to seek guidance and report concerns, and efforts to promote an ethical culture.
The Compliance Committee champions Amgen's culture of compliance and business ethics by ensuring it is the foundation of the company's strategy, goals and objectives. It is chaired by Bob Bradway, Amgen's chairman and chief executive officer, and comprised of Amgen's Operating Team. The Compliance Committee's responsibilities include reviewing key compliance risks and associated mitigation plans, ensuring that compliance and business ethics -related strategic initiatives are appropriately prioritized, resourced and tracked, overseeing the operation of the Compliance Council and ensuring that compliance performance is part of executive management reviews.
Chief Compliance Officer
As the Chief Compliance Officer, Nancy Grygiel leads and manages Amgen's Worldwide Compliance & Business Ethics Program and the centralized Healthcare Compliance organization. Nancy, who is the facilitator and a member of the Compliance Committee as well as the Compliance Council Chair, has the independence, authority and resources to assure the Elements of an Effective Compliance Program are in place to uniquely address Amgen's compliance risks and to effectuate change within the organization as necessary or appropriate. She presents an unbiased assessment of Amgen's state of compliance to the Corporate Responsibility and Compliance Committee of the Board of Directors (CRCC) several times a year. Nancy reports to Robert A. Bradway, Amgen's chairman and chief executive officer (CEO), and the CRCC.
The Compliance Council is a cross-functional body that analyzes compliance obligations and activities, implements Program improvements and provides information to the Compliance Committee and the Corporate Responsibility and Compliance Committee of the Board of Directors. The Compliance Council is comprised of senior level compliance professionals who are selected by the Compliance Committee to represent each functional area. Each Compliance Council Member is the liaison and ultimately responsible for ensuring that the Elements of an Effective Compliance Program are established within his/her Operating Team member's function. They report into their respective functional leadership while still maintaining accountability to the Chief Compliance Officer, who chairs the Council. Compliance Council Members are an important resource for staff members who have questions or are seeking guidance about compliance within their areas.