2017 CSR Report LEO Pharma A/S
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Contents LEO mission Contents — we help people MANAGEMENT’S STATEMENT achieve healthy skin Management’s Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Statement from the President and CEO. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Our business model. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 CSR Strategy 2017. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 CSR focus areas and goals 2017 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 MANAGEMENT’S REVIEW Environment, Climate and Energy Company information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Policies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Financial highlights . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Focus areas and achievements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 LEO vision Management’s Review. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 People, Health and Safety Policies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 — we are the preferred Focus areas and achievements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 FINANCIAL STATEMENTS 2015 Compliance and Ethics Consolidated Financial Statements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 Policies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 Parent Company Financial Statements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 Focus areas and achievements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 dermatology care Independent Auditor’s Report. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70 Partnerships and Collaborations Policies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 Focus areas and achievements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 partner improving Future plans Our CSR Commitment 2018-2020 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 CSR focus areas 2018-2020. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 Right to health . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 people’s lives around Right to privacy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 Mental well-being at work . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 Anti-corruption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 Responsible supply chain management. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 the world Other essential areas of our CSR commitment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48 People development. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 People safety. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 Climate change, environment and energy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52 Animal welfare. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 Our CSR governance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54 Glossary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56 Reporting approach. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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Statement from the President and CEO Statement from the President and CEO Taking CSR at LEO Pharma to the next level At LEO Pharma, we are committed to helping people New focus areas and overall CSR framework living with skin diseases. It is the focus of our mission, Based on thorough analysis, we have chosen the fol- vision and corporate strategy ‘Helping SARAH – LEO lowing CSR focus areas for 2018-2020: towards 2025’. Right to health, Right to privacy, Mental well-being at In 2017, we helped 80 million people, and we aspire to work, Anti-corruption and Responsible supply chain help more than 100 million people in 2020 and more management. than 125 million people in 2025. However, LEO Pharma’s CSR commitment encompasses Our determination to help people is also reflected in much more than these five focus areas. Animal welfare, our Corporate Social Responsibility (CSR) Commitment climate change, environment and energy, people safety 2018-2020, which was launched in December 2017. and people development are all essential areas too. Our efforts within these areas are therefore central to up- Throughout 2017, we developed our commitment in holding our high standards within CSR. collaboration with internal as well as external stake- holders. We listened to our stakeholders’ expectations We are equally committed to respecting human rights of us as a responsible global healthcare company and and supporting the UN Sustainable Development Goals assessed the business impact of relevant CSR areas, (SDGs), which are part of the overall framework for our before deciding on the scope of our CSR Commitment CSR work and are integrated into relevant CSR areas. 2018-2020. The result is a strategic and coherent framework for LEO Pharma’s future CSR work that This report gives an overview of our policies and CSR builds on our LEO values. achievements reflected in our CSR Strategy 2017 for the financial year 1 January – 31 December 2017 as Going forward, our ambition is to take CSR at LEO Pharma well as the future plans for our CSR Commitment 2018- to the next level in order to increase the positive impact, 2020. as well as minimise the adverse impact, we have on society and the environment. On behalf of the Global Leadership Team, “We helped 80 million people Gitte P. Aabo in 2017.” President and CEO 6
Our business model Our business model Our business model LEO Pharma develops and delivers innovative medicines and integrated care solutions to healthcare providers and people suffering from psoriasis, eczema, In 2017, we helped skin infections and actinic keratosis. We develop drugs, devices, delivery sys- tems and digital health technologies. We also offer solutions for conditions that require supportive treatment, such as thrombosis, kidney disease and cancer- 80 million people associated thrombosis. Patients Presence in 61 countries • Treatments available in more 6 manufacturing sites than 130 countries Finished goods produced in a year: • Innovative medicines, devices and • 68 million packs of aluminium tubes delivery systems We improve quality of life • 65 million syringes • Patient support programmes for patients and engage with: • 22.5 million packs of capsules • Regulators • 10 million packs of tablets • Payers • 8.2 million vials • Prescribers • 8 million packs of bottles Sales and distribution More than 700 • 3.8 million Fucidin® gauze • Other key stakeholders scientists and specialists • 0.645 million cans • LEO Pharma R&D • 0.375 million applicators • LEO Pharma Partnerships • 0.018 million biologics syringes • LEO Pharma Open Innovation External stakeholders • LEO Innovation Lab • LEO Science & Tech Hub Product supply Our foundation ownership Thanks to its foundation ownership, LEO Pharma is in a unique position to help people with skin diseases. Owned 100% by a private commer- cial foundation, the LEO Foundation, LEO Pharma is an independent company with no external shareholders. All profits are reinvested in the LEO Research and development Group with the aim of continually providing patients with better solutions – so that LEO Pharma can go further in its mission to help people achieve healthy skin. 7 8
Our CSR CSR approach Strategy 2017 CSR Strategy 2017 CSR Strategy 2017 Our CSR strategy for 2017 focuses on building a foun- Our approach to CSR is centred around four strategic dation for working more systematically with CSR at LEO CSR pillars: ‘Environment, Climate and Energy’, ‘People, Pharma. Health and Safety’, ‘Compliance and Ethics’ and ‘Partner- ships and Collaborations’. The purpose of the CSR strategy is to support our corp- orate strategy by ensuring that we run a sustainable To ensure progress within each of the four CSR pillars, a business. The overall ambition is to minimise the nega- number of focus areas have been identified. Each focus tive impact and increase the positive impact that we area is supported by goals. have on people and the planet. ENVIRONMENT, PEOPLE, HEALTH COMPLIANCE AND PARTNERSHIPS AND CLIMATE AND ENERGY AND SAFETY ETHICS COLLABORATIONS • LEO Pharma aims to • LEO Pharma aims to • L EO Pharma aims to be • L EO Pharma strives to protect the environment, have a safe and healthy a responsible corporate gain deeper insights into prevent pollution and working environment by citizen wherever the diseases and the needs promote efficient energy strengthening our safety Group operates. of patients to enhance the use. culture and by focusing on development of medical •A s a pharmaceutical psychosocial and physical products and solutions. • We seek to minimise company with high working conditions. emissions that ethical standards, we •W e are committed to contribute to global • We strive to support the take responsibility for engaging in partnerships warming, for example by continuous development our actions, and we and collaborations that implementing energy- of LEO people. recognise that we are can potentially improve the efficient solutions. accountable not only for lives of patients. • We support and respect what we do, but also for • We aim to minimise our the protection of •W e continue to how we do it. environmental impact internationally adopted improve our Third Party through continuous human rights, including •W e are determined Compliance Framework improvement activities the fundamental workers’ to strengthen our in order to strengthen and adherence to rights espoused by the compliance culture and our collaboration with international standards. International Labour behaviour by actively third parties and uphold Organization. engaging LEO people in high quality and ethical compliance. standards. 9 10
CSR focus areas and goals 2017 CSR focus areas and goals 2017 CSR focus areas and goals 2017 COMPLIANCE Focus area Goal for 2017 AND ETHICS To ensure progress within each of the four CSR pillars, a number of focus areas Strengthen the compliance −− Conduct global compliance culture survey. culture were identified. Each focus area has related goals. −− Conduct global compliance culture campaign. HCP compliance −− Create an overview of HCP/HCO spend data in countries with disclosure requirements. ENVIRONMENT, Focus area Goal for 2017 Work against corruption −− Conduct global anti-corruption and anti-bribery awareness campaign. and bribery CLIMATE AND ENERGY Reduce C02 emissions −− Implement energy efficiency projects corresponding to 5,200 MWh energy savings. Integrate management −− Merge local management systems covering ISO 14001, OHSAS 18001/ISO systems covering ISO 45001 and ISO 50001 into a global system. 14001, OHSAS 18001/ISO 45001 and ISO 50001 PARTNERSHIPS AND Focus area Goal for 2017 Carbon footprint related −− Have baseline on carbon footprint in place for at least one LEO product. COLLABORATIONS to LEO product Continue mutually −− Expand the Psoriasis Academy to include strong input from patient organisations. beneficial collaborations Waste reduction and −− Implement at least one new waste reduction and/or recycling project. with scientific and patient −− Continue project-based collaboration with scientific and patient organisations recycling organisations globally. Improve animal welfare −− Refine our psoriasis transplantation model. within the 3Rs (Replace- ment, Reduction and −− Replace skin sensitisation models with cell-based models. Refinement) −− Increase the animal welfare standards of our collaboration partners. −− Implement at least three new enrichment initiatives for our experimental PEOPLE, HEALTH Focus area Goal for 2017 animals. AND SAFETY Respect human and −− Conduct global awareness campaign about human rights. Enhance transparency in −− Submit a redacted Marketing Authorisation Application (MAA) in accordance labour rights clinical trials with European Medicines Agency (EMA) Policy 0070. −− Make LEO Pharma’s updated position paper on clinical trial transparency Strengthen occupational −− Adapt resilience and stress management initiatives implemented in Denmark publicly available. health in 2016 for global implementation. −− Publicly disclose summary of clinical trial results for laypersons. −− Implement adapted resilience and stress management initiatives globally. Third Party Compliance −− Update the procedure for third party compliance. Ensure ongoing personal −− Develop and run pilot for new performance and people development process Framework −− Continue implementing the procedure for third party compliance in affiliates.1 development of LEO in selected areas. people −− Continue to increase internal awareness of Third Party Compliance Frame- −− Develop and test concept for strategic competence development in selected work, incl. Third Party Compliance Code, at headquarters and affiliates. areas. Reduce LTI rate −− LTI rate at manufacturing sites ≤ 3.5. Community engagement −− Enter into at least one new partnership related to community engagement. 1 Concurrently with the roll-out of our ERP system. 11 12
Environment, Climate and Energy Environment, Climate and Energy Reduce CO2 emissions is closer to the point of use. The energy saving achieved LEO Pharma’s activities result in a number of solvents, by this project is estimated to be 80 MWh/year. acid gases and greenhouse gases being emitted into the air. In Ballerup (DK), a leaky steam safety valve was re- Environment, placed, which resulted in energy savings of 1,400 At LEO Pharma, we are committed to reducing our CO2 MWh/year. emissions to reduce our impact on climate change. We therefore encourage the minimisation of energy At the manufacturing sites in Dublin (IE) and Ballerup Climate and Energy consumption across our operations and monitor our (DK), a number of lighting projects were implemented, use of energy, which helps us improve our energy per- where old fittings were replaced with LED fixtures or formance. LEO Pharma’s use of energy constitutes one where the light source was simply changed to LED. The of its main environmental impacts. We therefore aim energy savings achieved by these projects were 300 to optimise our energy consumption across our oper- MWh/year. ations and have a 2020 goal to achieve a 10% energy reduction compared to 2013. In Vernouillet (FR), a chiller was replaced, resulting in en- ergy savings of 304 MWh/year. At LEO Pharma, we are committed to reducing the impact our business activities In 2017, one of our goals was to implement energy efficiency projects corresponding to 5,200 MWh in The energy savings generated from the various energy have on the environment. Protecting and preserving the environment is an integral energy savings, equalling approximately 273 Danish efficiency projects implemented amounted to 3,129 part of our daily business. households per year. In our efforts to achieve this goal, MWh, and our 2017 goal was therefore not achieved. a number of projects were implemented, including the following examples. This was mainly due to the fact that a planned main- tenance shutdown in Ballerup (DK), which should have Policies In Dublin (IE), a project to increase steam capacity within taken place in 2017, was postponed to the second the current steam distribution network was implement- quarter of 2018. The maintenance shutdown was the LEO Code of Conduct and Environment, Climate nificant environmental impacts have been selected. We ed. This resulted in improved efficiency due to reduced only window of opportunity to implement some of the and Energy Policy work to minimise these impacts, and how we do this is energy loss from the system as the point of generation major energy efficiency projects. In 2018, efforts to im- Our approach to reducing the negative impact our op- described in the following sections. plement the energy efficiency projects will be prioritised. erations have on the environment is governed by the LEO Code of Conduct, which includes our Environment, Climate and Energy Policy. The policy outlines our com- mitment to protecting the environment, preventing LEO Pharma’s environmental and energy impact Total consumption of energy at LEO Pharma’s manufacturing sites pollution and promoting efficient use of energy at LEO * Note that the report- Pharma. 2013 2014 2015 2016 2017* ing period for energy consumption has been Emissions The LEO Code of Conduct is mandatory for all LEO peo- Total in MWh 128,705 124,077 123,902 127,319 127,385 changed, see Reporting to air ple and is a framework for how we behave. The LEO approach. Code of Conduct is supported by internal communica- tion material to increase awareness among LEO people. New employees undergo mandatory training in the LEO Energy consumption – sources Code of Conduct shortly after their employment com- mences. 90,000 Use of energy 80,000 Waste 70,000 Focus areas and achievements LEO Pharma’s main impacts on the environment are Use of water 60,000 50,000 Note: Oil (for boilers), forklift its use of energy and water; generation of waste and gas, and diesel and petrol waste water; and direct and indirect emissions of green- 40,000 for cars/trucks are not 2013 Waste water house gases and other emissions to air. These impacts included. They usually 30,000 account for less than 0.6% are mainly generated through our production activities, 2014 which take place at six manufacturing sites in Ballerup (2010-2015) of the total 20,000 2015 energy consumption and and Esbjerg in Denmark, Dublin and Cork in Ireland, Ver- 10,000 2016 have accounted for less nouillet in France and Southport in Australia. On page 58, than 0.3% over the past four we describe the criteria based on which the most sig- 0 2017 years. Natural gas Electricity District heating MWh/year 13 14
Environment, Climate and Energy Environment, Climate and Energy DID YOU KNOW? LEO Pharma has merged its local EHS man- agement systems into one global system to standardise procedures and reduce internal Integrate management systems covering ISO Waste reduction and recycling complexity. 14001, OHSAS 18001/ISO 45001 and ISO At LEO Pharma, we aim to have no waste to landfill 50001 by 2020. To achieve this goal, we plan to identify Another goal for 2017 was to merge local manage- and implement waste reduction projects in order to ment systems covering ISO 14001, OHSAS 18001/ sustain more than 97% of our generated waste be- ISO 45001 and ISO 50001 into a global system. This ing recycled. goal was achieved. The integrated global environ- ment, health and safety (EHS) management system In 2017, we implemented the following new waste became effective on 29 December 2017. reduction project. At our manufacturing site in Ver- nouillet (FR), syringes are received on polystyrene supports. Until 2016, this material was reused at several stages of the production process. However, Certifications – manufacturing sites the material is very fragile and only made it through 75% of the total production process. As a conse- ISO 14001 ISO 50001 quence, it had to be regularly changed and discard- ed. In 2017, a new type of material was introduced Ballerup (DK) 2014 Expected 2018 which is made from another kind of plastic mate- 2014 Expected 2018 rial (APET, amorphous polyethylene terephthalate). Esbjerg (DK) This material is stronger and will serve the same Vernouillet (FR) 2011 Expected 2019 purpose, but will cover almost two production cy- cles. In 2016, we produced 145 tons of waste from Cork (IE) 2015 Expected 2018 the previously used material. The new material was introduced in 2017 and, compared to the figure Dublin (IE) 2012 2010 from 2016, it is expected that the waste volume for this material will be halved going forward. Southport (AU) 2015 No plans By implementing this project, we achieved our 2017 Note: The year indicates when the certifications were obtained. goal to implement at least one new waste reduction Recertifications are needed every three years. For example, certifications obtained in 2014 were recertified in 2017. and/or recycling project. Use of water In addition to working to achieve the four goals The benefits of having one integrated system are described above, we also worked to reduce the many. Merging separate systems into one helps us amount of water used in our manufacturing pro- drive EHS performance and reduces internal com- cesses, in the composition of products and for plexity related to operating under various systems. cleaning and sanitary purposes. Our 2020 goal It also minimises the general workload by reducing for water savings is to reduce consumption by 5% Focus area Goal for 2017 Status 2017 the number of required procedures and creates a compared to the water usage in 2013. As a step to- unified approach to EHS management in line with wards achieving this, we implemented the following Reduce C02 emissions −− Implement energy efficiency projects corresponding to 5,200 MWh energy Not achieved our LEAN approach to continuous improvements. initiative in 2017. At our manufacturing site in Cork savings. (IE), an additional site water meter and alarms for Carbon footprint related to LEO product Integrate management −− Merge local management systems covering ISO 14001, OHSAS 18001/ISO Achieved increased usage and leak detection were installed. Our goal to have a carbon footprint baseline in place systems covering ISO 45001 and ISO 50001 into a global system. for at least one LEO product was also achieved in 14001, OHSAS 18001/ISO Waste water 45001 and ISO 50001 2017 with the completion of a carbon footprint Waste water is generated by our production, clean- baseline for one of our products for thrombosis, Carbon footprint related −− Have baseline on carbon footprint in place for at least one LEO product. Achieved ing and sanitation activities. The waste water is innohep ®. Product carbon footprints give us an to LEO product sent to municipal treatment facilities for purifica- overview of our negative environmental impact and tion before it is discharged into the sea or rivers. Waste reduction and −− Implement at least one new waste reduction and/or recycling project. Achieved make it possible to prioritise our efforts to protect recycling the climate. We expect carbon footprint documen- tation to be a competitive factor in the future, as the market comes to demand this kind of information. 16 15
People, Health and Safety People, Health and Safety DID YOU KNOW? People, Health and In 2017, LEO Pharma’s annual employee engage- ment survey, LEO Voice, achieved a sustainable Safety engagement score of 84%. This reflects an organisation of highly engaged employees committed to making a difference to people with skin diseases. LEO people form the basis for LEO Pharma’s success. The skills and com- petences of our global workforce are some of our most important assets, and we will therefore not compromise the human and labour rights or the occupational health and safety of our employees. We continuously work to provide a safe and healthy working environment for LEO people, regardless of where they work. Policies To raise awareness of human rights, we set a goal for 2017 to conduct a global human rights awareness LEO Code of Conduct and policies campaign as part of our preparations to work with the The LEO Code of Conduct includes our Occupational UN Guiding Principles on Business and Human Rights A/S (in addition to the employee-elected board mem- In 2017, ‘Mental well-being at work’ was chosen as one Health and Safety Policy as well as our Human and La- (UNGPs). As our future CSR Commitment 2018-2020 bers) by 2019. With the appointment of one additional of the five focus areas of our CSR Commitment 2018- bour Rights Policy. includes our commitment to respect human rights, it female board member in 2017, this goal was achieved. 2020. Plans for the focus area include a global focus was decided to include the global human rights aware- A new goal will be set at the beginning of 2018. on resilience and stress management. Read more on LEO Pharma provides a safe and healthy work environ- ness campaign in the overall communication of our pages 42-43. ment for LEO people and visitors, in accordance with CSR Commitment 2018-2020, which was launched in At management levels (in total) below the Board of Dir- applicable laws and international standards. We also December 2017 (read more on page 32). ectors of LEO Pharma A/S, each gender is equally rep- In 2016, we postponed until Q1 2017 our milestone to support and respect the protection of internationally resented by at least 40%. establish a project team at our headquarters to identify adopted human and labour rights, including the Interna- In 2017, working with human rights at LEO Pharma in- how to collect data on absenteeism due to factors in the tional Bill of Human Rights, the Universal Declaration of cluded a pilot project for implementing the UNGPs. The Strengthen occupational health psychosocial working environment. Data on absentee- Human Rights and the fundamental workers’ rights es- pilot project was a human rights impact assessment of In 2016, the aspect of occupational health encapsulat- ism due to factors in the psychosocial working environ- poused by the International Labour Organization (ILO). our Global People function at headquarters. The human ing work-related stress and organisational resilience ment were collected at headquarters. However, we are rights impact assessment consisted of mapping pol- was a milestone for our CSR efforts in Denmark, cover- still investigating how to collect data globally. The LEO Code of Conduct is mandatory for all LEO peo- icies and processes, analysing gaps with reference to ing a range of different initiatives. ple and provides guidance for our behaviour. New em- the 48 human rights and developing action plans based Ensure ongoing personal development of LEO people ployees undergo mandatory training in the LEO Code of on the findings. The findings were presented to the LEO In 2017, our goals were to adapt these resilience and In 2017, our goal to develop and run a pilot for a new Conduct shortly after their employment commences. Compliance Board. In 2018, LEO Pharma will work on stress management initiatives implemented in Den- performance and people development process in se- implementing the defined actions to mitigate our identi- mark in 2016 for global implementation, and imple- lected areas was partly achieved. A global performance Focus areas and achievements fied potential and actual impacts on human rights. Start- ment the adapted resilience and stress management management process was developed to support ongo- ing in 2018, the next step is to expand the human rights initiatives globally. These goals were partly achieved, as ing and forward-looking dialogue between managers Respect human and labour rights impact assessment to the rest of headquarters. resilience and stress management initiatives were initi- and employees regarding performance and develop- At LEO Pharma, we support and respect human and la- ated and carried out in various countries – both for man- ment, linking business priorities and values with em- bour rights. We also support a non-discriminating and Statutory Report on Gender Diversity of Management, agers and employees. Examples from Ireland and the ployee actions. The process will be piloted in 2018 in inclusive workplace, and we embrace diversity at all cf. Section 99b of the Danish Financial Statements Act UK include sessions on managing stress at work, mind- selected business areas within LEO Pharma. levels of the organisation. In 2015, we set the goal to have at least two female fulness sessions and techniques, tools to help identify board members on the Board of Directors of LEO Pharma signs of stress and general focus on mental well-being. 17 18
People, Health and Safety People, Health and Safety Another goal for 2017 was to develop and test a con- safety culture and track the progress of our efforts to cept for strategic competence development in selected provide a healthy and safe working environment. areas. The achievement of this goal has been post- Currently, the LTI rate is only measured at our manufac- Overall trend at manufacturing sites No. of lost time injuries (LTIs) poned. The development of a concept for strategic turing sites. No. of lost days competence development has now been integrated No. of LTIs No. of lost days into one of our strategic projects to support the imple- Our goal is to have an LTI rate of ≤ 2 for the LEO Group mentation of LEO Pharma’s 2025 strategy2. in 2020, and we therefore work to improve our LTI rate 30 450 year on year. 400 In 2017, we launched a new concept for working with 25 employee engagement at LEO Pharma. LEO people 350 form the basis for our company’s success, and employ- 20 300 ee engagement is key in order to achieve LEO Pharma’s goals. With the new concept, we will conduct an annual LTI rate trend at manufacturing sites 250 15 employee engagement survey, supplemented by two 200 mini-surveys. This way, we aim to ensure that employee LTI rate engagement and well-being become topics for ongoing 7 10 150 conversations within all teams across the global organi- 7.9 7.7 6.5 100 sation and that actions are taken proactively to address 6 5 issues and challenges. 50 5 5.3 0 0 In 2017, LEO Pharma’s top 100 leaders also complet- 2013 2014 2015 2016 2017 Year 4 4.3 4.2 ed the leadership development programme ‘Leading 4.1 Execution’. With the purpose of improving execution 3 capabilities, the programme focused on building new competences and implementing new behaviours in 2 daily routines. As a result, more than 70% of the lead- Lost time injuries (LTIs) 2013-2017 ers achieved a clear improvement in their ability to 1 execute strategy. In summer 2017, Leading Execution 2013 2014 2015 2016 2017 0 was kicked off for an additional batch of 280 leaders 2013 2014 2015 2016 2017 Year globally. No. of LTIs 26 21 18 19 19 No. of lost days 348 388 298 343 200 Reduce LTI rate Our ambition is for no LEO people to get injured at work. As the graph shows, our LTI rate has been declining It is important for us to ensure that when people come year on year. In 2017, our goal was to have an LTI to work, they and their families can be confident that rate at our manufacturing sites of ≤ 3.5. However, We are moving in the right direction, but we still training workshops were held across all manufac- they are going to go back home at the end of the day our LTI rate remained almost the same as in 2016. have some challenges regarding our LTI rate and turing sites. This type of training will continue in the safe and well. We did not achieve the 2017 goal since the LTI rate the number of injuries at the larger manufacturing coming years. As part of the training, a new train- ended on 4.1. sites which need attention. However, we have seen ing video was introduced, which supports the LEO To strengthen and accelerate the LEO people safety a significant drop in the number of lost days due to Code of Conduct and the principle of always putting journey, more focus has been added to the area. For an injury, which says something about the severity safety first. This video will be used across the or- example, the Global Environment, Health and Safety of the injuries incurred. ganisation going forward. (EHS) function and local Danish EHS were merged in 2017 to benefit from gathering EHS competences in In 2017, we continued to identify and record haz- In 2017, we also introduced a new global system- one place. By joining forces, we created an EHS Centre ards. The number of closed hazards was almost atic approach to following up on and investigating of Excellence within LEO Pharma with a stronger basis as high as in 2016. Furthermore, we intensified our injuries, where we apply LEAN tools during the in- for continuous EHS improvements. This is a significant work to proactively increase the safety awareness vestigation. The purpose is to dig deeper into the step in further demonstrating our commitment to driv- level through a number of initiatives. root cause of an injury and share the solutions in a ing necessary safety improvements. systematic way across sites. Besides systematical- One of the leading initiatives in 2017 was to train ly investigating and analysing injuries, GEMBA on all To support our people safety ambition and journey, we managers in EHS awareness and their obligations LTIs was also introduced in 2017. The term GEMBA 2 LEO Pharma’s new 2025 strategy was communicated in 2017 and entails focusing on medical dermatology bringing new, set ambitious goals. Among other things, we use the innovative treatments forward and helping meet the individual needs of people living with a skin disease. Read more about our related thereto. Manager support is key to achieving means to go to where the injury took place and talk Lost Time Injury (LTI) rate to measure LEO Pharma’s 2025 strategy in LEO Pharma’s Annual Report 2017. our safety goals, and consequently manager safety to the people who were involved. The rationale is 19 20
People, Health and Safety People, Health and Safety that this increases awareness and helps provide an A way of ensuring that we continuously improve understanding of why it happened, hence increas- our occupational health and safety standards and ing the quality of the implementation of preventive focus on the safety of our employees is through actions. One important ambition in 2017 was to upholding a safety management standard. LEO have management follow up on all LTIs. We suc- Pharma holds OHSAS 18001 certifications at all its ceeded in fulfilling this ambition. manufacturing sites – this was achieved in 2014 and is important for us to maintain. At our site in Vernouillet (FR), the EHS function was relocated to the production area in order to be close The CSR Report 2016 stated that we expected to to people on the shop floor. This will create more prepare for ISO 45001 certification throughout visibility, and EHS professionals will be able to inter- 2017. Preparing for the new ISO 45001 health and act more closely with the people at the factory. At safety management standard also pushes us in the the same site, EHS process confirmation was intro- right direction. However, as the ISO 45001 standard duced, focusing on behavioural observations. Man- will only come into force in the first quarter of 2018, agers go to the shop floor, observe and enter into a our deadline was postponed too, and there will be dialogue with employees by asking questions. The a transition period during which the manufacturing purpose is to understand root causes and the safe- sites will work to meet the requirements of the new ty behaviour of employees and to increase safety standard. awareness through face-to-face dialogue. In Ballerup (DK), we are currently working on sev- eral improvement projects, for example upgrading the API facility, where safety is our first priority. This Certifications – manufacturing siites means great involvement and awareness from both the EHS function and managers. Due to this, people OHSAS 18001 increasingly talk about safety across the site and proactively seek EHS advice. Ballerup (DK) 2010 Esbjerg (DK) 2010 In Dublin (IE), we increased our focus on reporting all injuries, no matter how minor, and simple, visual 2014 Vernouillet (FR) safety alerts for each of these injuries were issued to all employees to heighten general safety aware- Cork (IE) 2013 ness and to prevent recurrences. To ensure that a ‘safety first’ philosophy is firmly embedded in every Dublin (IE) 2014 corner of the business, we also conducted safety Southport (AU) 2014 walks and toolbox talks. Furthermore, a process for safety reviews was conducted as part of a global Focus area Goal for 2017 Status 2017 Note: The year indicates when the certifications were obtained. EHS initiative to identify areas of site operations that Recertifications are needed every three years. For example, need further investment in safety improvements. certifications obtained in 2014 were recertified in 2017. Respect human and −− Conduct global awareness campaign about human rights. Included in another labour rights campaign In general, we found that all manufacturing sites Strengthen occupational −− Adapt resilience and stress management initiatives implemented in Denmark Partly achieved increased their focus on safety in 2017. As men- health in 2016 for global implementation. tioned, the greatest challenges are for the larger sites, which is the reason why the safety work car- −− Implement adapted resilience and stress management initiatives globally. Partly achieved ried out at these sites is highlighted in this report. However, various efficient safety initiatives were Ensure ongoing personal −− Develop and run pilot for new performance and people development process Partly achieved development of LEO in selected areas. implemented at our manufacturing sites in Esbjerg people (DK), Cork (IE) and Southport (AU), such as focus −− Develop and test concept for strategic competence development in selected Postponed on emergency response, hazard identification and areas. awareness, better traffic flows on site and electri- Reduce LTI rate −− LTI rate at manufacturing sites ≤ 3.5. Not achieved cal safety improvements. In fact, these sites have not had any LTIs for several years. 21 22
Compliance and Ethics Compliance and Ethics knowledge, or to support medical research. To ensure In 2017, anti-corruption was chosen as one of the five internal transparency and understanding of the types focus areas of our CSR Commitment 2018-2020. Read Compliance and amount of transfers of value made to HCPs and more about our future plans for this area on pages 44-45. HCOs, our goal for 2017 was to create an overview of HCP/HCO spend data in countries with disclosure re- quirements. This goal was achieved. An overview of and Ethics HCP/HCO spend data was created based on the data uploaded to our reporting tool, STAR, and the HCP/HCO spend data overview will be shared with relevant inter- nal stakeholders in 2018. Work against corruption and bribery In 2017, we also had a goal to conduct a global anti- corruption and anti-bribery awareness campaign. This As a responsible pharmaceutical company, it is important for us to uphold high goal was achieved in April, when we completed our in- ternal awareness campaign. ethical standards. Together with our values – Integrity, Customer focus, Innova- tion, Passion and Adaptability – the LEO Code of Conduct provides clear guid- The purpose of the campaign was to increase aware- ness of anti-corruption and anti-bribery among LEO ance for our behaviour and the way we do business. people. The campaign built on a variety of updated communication materials, films and articles which gave Policies Focus areas and achievements external experts’ views on corruption. The campaign was supported by an event with the involvement of our LEO Code of Conduct and Anti-Corruption and Anti- Strengthen the compliance culture top management and an external speaker, and this was Bribery Policy In 2017, our goals to conduct a global compliance cul- shared with the entire organisation by video. The aim of The LEO Code of Conduct is mandatory for all LEO peo- ture survey and conduct a global compliance culture the event was to give employees a holistic overview of ple and is a framework for how we behave. New em- campaign were redefined, as we decided to take a the consequences of and examples related to corrup- ployees undergo mandatory training in the LEO Code of step back and look at how to design compliance at LEO tion, and how corruption impacts not only the business Conduct shortly after their employment commences. Pharma before initiating specific compliance culture ac- environment but also the lives of patients, the environ- tivities. As a consequence, the two goals were replaced ment and society at large. Corruption and bribery are illegal and contrary to our val- by a larger global project. ues and ethical standards. We avoid and work against corruption and bribery. This is reflected in the LEO Code Throughout the first half of 2017, we conducted a global of Conduct as well as in our Anti-Corruption and Anti- compliance project with the scope of defining the future Bribery Policy, in which all employees are trained. compliance ambition at LEO Pharma. Four key object- ives were identified. Going forward, we will focus on Another important compliance area is interaction with building the future governance structure for compli- healthcare professionals (HCPs) and healthcare organi- ance at LEO Pharma, driving the compliance culture, sations (HCOs). Interaction with HCPs must be conduct- managing compliance risks and upgrading processes, ed in a truthful manner, avoiding deceptive practices tools and systems – thereby making compliance an in- and potential conflict of interest. Guidelines on how we tegrated and strategic part of doing business. To drive interact with HCPs are included in our Interaction with this progress, the position of Chief Compliance Officer is Healthcare Professionals in relation to Pharmaceuticals being created. Policy as part of the LEO Code of Conduct. Focus area Goal for 2017 Status 2017 In 2017, we also implemented our new business docu- We focus on improving our compliance culture and eth- ment management solution, MyDoc LEO, which provides Strengthen the compliance −− Conduct global compliance culture survey. Replaced by another project culture ical behaviour. The LEO Compliance Board oversees the various KPI reporting options that will enable managers −− Conduct global compliance culture campaign. Replaced by another project development and implementation of important strate- to maintain the necessary overview, be in compliance gic compliance initiatives and sets the strategic direction and be prepared for audits. HCP compliance −− Create an overview of HCP/HCO spend data in countries with disclosure Achieved for strengthening and supporting the compliance com- requirements. munity across the organisation. In addition, we regularly HCP compliance Work against corruption −− Conduct global anti-corruption and anti-bribery awareness campaign. Achieved assess risks including corruption and bribery in relation At LEO Pharma, we interact with HCPs in order to pro- and bribery to our industry and the countries in which we operate. vide or obtain scientific or educational information and 23 24
Partnerships and Collaborations Partnerships and Collaborations Partnerships and Collaborations At LEO Pharma, we acknowledge the importance of collaborating with external partners to develop the best solutions. By engaging in partnerships and col- laborations with relevant stakeholders, LEO Pharma and its partners are able to draw on their mutual expertise and resources to help people with skin diseases. Policies LEO Pharma collaborates with a multi-disciplinary glob- al faculty led by thought leaders in the development LEO Pharma Third Party Compliance Code and facilitation of this train-the-trainer programme. The The LEO Pharma Third Party Compliance Code defines expertise of the faculty includes dermatology, psychol- the minimum requirements for third parties in relation to ogy, psychodermatology, patient communication/em- business ethics, human rights, labour rights, health and powerment, dermatology nursing and, finally, patient safety, environment, subcontractors and management advocacy with the involvement of patient organisations systems in relation to these areas. Third parties work- in the global faculty. ing with or on behalf of LEO Pharma are expected to The focus of the presentation will therefore be to high- Research methods and technology are advancing all comply with our Third Party Compliance Code as well The educational programme has expanded globally, light the importance of enhancing communication be- the time. This also means that new options arise to as with applicable laws and regulations, and to uphold with its world summit in 2016 and regional summits in tween doctors and people living with psoriasis. The aim replace even more advanced animal models with cell- high quality and ethical standards. We may require third 2015 and 2017, providing a forum for dermatologists for 2018 is to integrate people living with psoriasis into based models and computer simulations, and we are parties to review operations and develop, document to share knowledge and experience with regional and the programme, further develop additional tools and seeing a general trend towards more cell-based mod- and implement plans to remedy any non-compliance. international experts. The agenda of the summits is to confirm the expected improved patient outcome. els. In 2017, we had a goal to replace our skin sensitisa- understand the challenges people living with psoriasis tion models with cell-based models. The achievement Focus areas and achievements face, review how psoriasis is being managed and how Read more about how the Psoriasis Academy supports of this goal as well as the related investigation of options this can be enhanced, and share real-life challenges. our CSR focus area 2018-2020 ‘Right to health’ on pages to replace skin sensitisation models have been put on Continue mutually beneficial collaborations with The focus is also to take an in-depth look at improving 36-37. hold. This is due to the fact that our strategy is to focus scientific and patient organisations patient outcome, with the focus on addressing the com- on systemic treatment of skin diseases, and skin sensiti- According to the 2016 WHO Global Report on Psoriasis, plexities of adherence and how some of the barriers Improve animal welfare within the 3Rs (Replacement, sation is only relevant for topical pharmaceuticals. low adherence is partly due to insufficient communi- could be overcome. Reduction, Refinement) cation between doctor and patient regarding instruc- At LEO Pharma, we focus on improving our animal wel- Another goal set for 2017 was to increase the animal tions on how to use the drug prescribed. Holistic care is In 2017, our goal was to expand the Psoriasis Academy fare standards for experimental animals in all aspects of welfare standards of our collaboration partners, which therefore needed due to the complexity of psoriasis, for to include strong input from patient organisations. This the 3Rs: Replacement, Reduction and Refinement. is an ongoing activity for us. When we partner with which prescribing drugs in isolation is insufficient. goal was achieved. Our goal to continue project-based small as well as large contract research organisations collaboration with scientific and patient organisations In 2017, we achieved our goal to refine our psoriasis (CROs), we want to make sure that they meet our high LEO Pharma’s Psoriasis Academy offers a global pro- globally was also achieved by involving these in the transplantation model in mice. This was done by opti- animal welfare standards. We therefore try to demand gramme to improve the consultation dialogue between Psoriasis Academy. mising anaesthesia and pain treatment after surgery in higher standards and choose CROs with high animal people living with psoriasis and their healthcare practi- order to improve the recovery and therefore the welfare welfare standards when entering into a new partner- tioners. The programme provides communication strat- The strong partnerships with patient organisations of the mice. This method is now fully implemented in our ship. All our collaboration partners meet EU standards, egies that will help empower people to take control of were exemplified by having the academy presented at research activities and has resulted in improved animal and some have even higher standards. However, we their condition. a breakfast symposium during the 5th World Psoriasis welfare. still engage with collaboration partners to further im- & Psoriatic Arthritis Conference in 2018. 25 26
Partnerships and Collaborations Partnerships and Collaborations prove the welfare of experimental animals. For exam- ple, we increased animal welfare standards for ferrets at our collaboration partners in the US in 2017. We did Posted report synopses and clinical trial reports per disease area DID YOU KNOW? this through dialogue at physical audits and follow-up to ensure that our requirements were implemented. Disease Report synopses Clinical trial reports In 2017, AllTrials ranked LEO Pharma in sec- At LEO Pharma, we find that high animal welfare results Actinic keratosis 31 25 ond position, leading the global pharma in- in higher scientific quality. Research also backs up our dustry in commitments to increase access observations, as non-stressed animals have stronger Alopecia areata 1 0 to clinical trials information. immune responses and there is less standard variation Atopic dermatitis and eczema 5 2 within the experimental groups3. Enrichment is one way AllTrials is an international campaign that to provide the animals with a non-stressed environ- Hypertension and edema 7 7 calls for every clinical trial, past and pre- ment with options for expressing natural behaviour. sent, to be registered and its results re- We therefore continuously work to improve the variety Psoriasis 78 71 ported. The rankings assess companies’ of enrichment initiatives and, in 2017, our goal was to policy commitments on disclosing trial Secondary hyperparathyroidism 2 2 implement at least three new enrichment initiatives for registrations, summary findings of studies, our experimental animals. We implemented more than Skin infection 15 15 comprehensive clinical study reports and three enrichment methods, for example LEGO® DUPLO®, individual patient data. table tennis balls and cardboard tubes with food enrich- Thrombosis 10 11 ment, and achieved the goal set. Urinary tract infection 2 2 In addition to the goals described above, we also imple- Healthy subjects 52 45 mented micro blood sampling in all our rodent models, which means that blood samples are collected under Total 203 180 less stressful conditions as only a very small amount of in clinical trials. Our position paper applies to LEO- We actively work to ensure third party compliance blood is required for analysis. So far, LEO Pharma is the sponsored interventional clinical trials from our and recognise that it is important in order to main- only research facility in Denmark to use this method. documents in marketing authorisation applications entire clinical research and product portfolio, and tain the trust of our stakeholders and protect LEO (MAA) submitted via the centralised procedure. covers obligations relating to public data registries, Pharma’s reputation. Enhance transparency in clinical trials result reporting on the corporate website, publica- LEO Pharma was among the first companies globally to In 2017, one of our goals was to submit a redacted tion in peer-review journals, individual patient data We continuously improve our Third Party Compliance commit to increased transparency in clinical research. MAA in accordance with EMA Policy 0070. This goal sharing, and disclosure of submission components. Framework to ensure that we work systematically We register all our clinical trials and make the results of was set under the assumption that the EMA would with third parties. the trials, dating back to 1990, available to the public. request the redacted file according to the proce- As a patient-focused company, we are committed We also share individual patient-level data upon re- dures set out in the Policy 0070 implementation to communicating the results of our clinical trials In 2017, our goal to update the procedure for third quest from qualified third-party researchers. guideline. LEO Pharma has still not received the at a level that is understandable for the patients party compliance was achieved. Through close col- notification to submit the redacted document pack- participating in the trials and for the general pub- laboration between relevant internal stakeholders, By the end of 2017, 203 report synopses and 180 clin- age, but we are prepared to react promptly upon lic. In 2017, an important step in making our clini- the existing procedure for third party compliance ical trial reports were publicly available. request. cal research transparent, accessible and available was replaced by a sustainable procurement proce- to everyone was our goal to publicly disclose a dure. The area of transparency in clinical research is LEO Pharma was the first Danish pharmaceut- summary of clinical trial results for laypersons. We rapidly changing. Today, clinical trial disclosure in- ical company to go public with its commitments achieved this goal in December 2017. In developing The update was necessary in order to reflect the cludes much more than registration of trials and to increased clinical trial transparency, with its the summary, we used patient feedback as well as changes in the procedure in recent years. Further- reporting of their results on various publicly avail- first position paper published in October 2013. In the EU Commission 2017 guideline ‘Summaries of more, the new procedure is simpler and higher able registries, such as the US clinicaltrials.gov and 2017, another goal was to make LEO Pharma’s up- Clinical Trial Results for Laypersons’. level, which makes it relevant for more employees the European Clinical Trials Registry. Many of the dated position paper on clinical trial transparency and, consequently, a tool for broader internal com- voluntary initiatives by trial sponsors have been publicly available. We achieved this goal in March Third Party Compliance Framework munication. Roles and responsibilities have been supplemented by global regulatory requirements, 2017, when we released a new position paper on Collaborating with third parties is part of our every- clarified, sections on how yearly assessments are with the emphasis on public disclosure of the actu- Public Access to Clinical Trials Information to ad- day operations, and we encourage engagement in performed have been added, and we have included al trial documentation. An example is the European just to growing requirements and to show the way business relationships which are built on trust, mu- a procedure for how to handle issues of non- Medicines Agency (EMA) Policy 0070, the scope of forward. With patients and research in mind, LEO tual respect and shared values. compliance with the LEO Pharma Third Party Com- which is public disclosure of the clinical submission Pharma has committed to enhancing transparency pliance Code. 3 Indian J Exp Biol. 1991 Mar;29(3):233-6. Effects of stress on immune responsiveness, gastric ulcerogenesis and plasma corticosterone in rats: modulation by diazepam and naltrexone. Ray A1, Mediratta PK, Puri S, Sen P. Brain Behav Immun. 2016 Sep 12. pii: S0889-1591(16)30419-6. doi: 10.1016/j.bbi.2016.09.010. [Epub ahead of print]. The commensal microbiota exacerbate infectious colitis in stressor-exposed mice. Galley JD1, Parry NM2, Ahmer BM3, Fox 27 JG2, Bailey MT4. 28
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