CSL Limited Annual Report 2021/22 61 Ethics and transparency While our CSL Values serve as the directional compass of our work, our Code of Responsible Business Practice (Code) provides a more detailed map to deliver on our promise to patients and public health in ways that exemplify the highest standards of conduct throughout the organisation. CSL’s Code fosters a culture that rewards high ethical standards, personal and corporate integrity and respect for others. Following the publication of the Board- endorsed 4th-edition Code on 1 July 2021, all employees were required to undertake training on the Code and CSL’s new ethics-based decisionmaking tool. These two e-learning modules were made available in 14 languages to cater for CSL’s global workforce. In certain aspects of our business, such as the marketing of our products, our relationships with healthcare professionals or healthcare organisations and our research and development, we have made further commitments to comply with both local and internationally accepted pharmaceutical industry codes of conduct. We expect third parties with which we work to comply with the applicable local laws and regulations of the countries in which they operate, and to observe all of the principles set out in our Code. We have internal control systems to ensure financial statements comply with the applicable local laws of the countries in which we operate and to prevent fraud and other improper conduct. CSL’s Code can be found on CSL.com (Our Company > Corporate Governance > Code of Responsible Business Practice). Anti-Bribery and anti-corruption CSL businesses and employees are prohibited from directly or indirectly offering, paying, soliciting or accepting bribes or giving or receiving personal favours, financial or other rewards or inducements in exchange for making business decisions. This prohibition applies regardless of the value of the reward or inducement. CSL policy also prohibits facilitation payments. CSL operates in a diverse and complex marketplace where bribery and corruption are risks that could expose the organisation and employees to possible prosecution, fines and imprisonment. CSL has a number of commercial arrangements with governments and related agencies across various geographies. Market practices are governed by company-specific policies and procedures. Internal compliance mechanisms and control systems are directly supported by our Global Ethics and Compliance team and subject to additional oversight by CSL’s Global Compliance Committee (GCC), regional committees, and CSL’s Audit and Risk Management Committee of the Board. Based on these controls, CSL considers our overall risk relating to corruption to be low and are committed to ensuring full compliance in how we conduct our operations across all regions in which we operate and those we are seeking to enter. From 1 July 2021 to 30 June 2022, 295 reports were identified for the attention of management through our global hotline. For substantiated allegations, corrective actions were taken to the extent warranted. For matters closed during the reporting period, no allegations resulted in any regulatory action or action by law enforcement authorities. In addition, over the reporting period, an annual assessment of bribery and corruption risk was conducted. This was achieved by means of a standardised questionnaire that was completed and the responses reviewed with the GCC. During the reporting period, the assessments did not identify any material issues with the CSL’s management of corruption risks. 295 hotline reports received, as at 30 June 2022, with no allegations resulting in regulatory action or action by law enforcement authorities. Fair competition In April 2022, the Romanian Competition Council (RCC) issued a decision fining five pharmaceutical companies, including CSL Behring GmbH, as well as the representative trade association of the plasma protein sector (PPTA) for claimed coordinating actions on the market. CSL Limited strongly disagrees with and contests the RCC’s findings and sanctions against the five companies and the trade association, and CSL has appealed the decision and will vigorously defend against the claims. For more than 100 years, CSL has earned its reputation as a trusted, reliable and ethical global organisation. CSL is proud of its robust compliance program and has established a track record of operating in compliance with all applicable laws. Political contributions Over the reporting period, CSL contributed a total of A$9,100 to political organisations in Australia solely for attendance at events including policy briefings, lunches, boardroom lunches and dinners. In all other regions, CSL made no political contributions. More at CSL.com (Our Company > Corporate Responsibility > Marketplace).
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