Performance by Technical Area

Has a strong access-to-medicine strategy with board-level responsibility. Novo Nordisk is one of 14 companies that performs strongly with regard to its access-to-medicine strategy, which includes access-related goals and aligns with its corporate strategies. For example, its strategy on improving access to diabetes care focuses on availability and affordability, building capacity in health systems and increasing access for the most vulnerable. The highest level of responsibility for access sits with a board-level committee.

Financial and non-financial access-related incentives to reward employees. Novo Nordisk performs strongly in encouraging employees to work towards access-related objectives. It is one of 14 companies to have both financial and non-financial incentives in place to motivate employees to perform on access-related issues. These incentives include bonuses for employees who perform remarkably and a long-term share-based incentive programme. Senior management has a separate incentive that supports the company's long-term access oriented objectives.

One of 16 companies working on impact measurement. Novo Nordisk measures and monitors progress and outcomes of access-to-medicine activities. It also publicly reports on commitments and performance information. For example, for its Changing Diabetes in Children initiative, the company reports on its performance, and its access to insulin commitments. Furthermore, it is one of the companies that is measuring impact by evaluation of its Base of the Pyramid initiative. 

Discloses who it engages with, incorporates local perspectives into strategies. Novo Nordisk publicly discloses which stakeholder groups it engages with on access issues, as well as its process for selecting who to engage with. It selects by following its stakeholder engagement plan prioritising stakeholders relevant for access to medicine, in close collaboration with relevant local offices. Local perspectives are incorporated into the development of access strategies. It has some policies covering responsible interactions with stakeholders, namely to comply with principles for stakeholder engagement to long-term business success, based on transparency and collaboration. 

Has measures to ensure third-party compliance with ethical marketing and anti-corruption standards. Novo Nordisk has a code of conduct relating to ethical marketing and anti-corruption. It provides annual compliance training for employees. The company provides evidence of having formal processes in place to ensure compliance with standards by third parties. Sales agents' rewards are not solely based on sales targets. Instead, it rewards other qualities such as technical knowledge and leadership competencies. 

Internal control framework meets some Index criteria. Novo Nordisk's internal control framework to ensure compliance meets some of the criteria looked for by the Index. Namely, it has an auditing and review mechanism in place, involving both internal and external resources, that also applies to third parties.  It does not, however, report fraud-specific risk assessments, nor does it demonstrate evidence of a monitoring system for non-compliance in the workplace, or procedures to segregate duties, to ensure decisions are checked by another party.   

Above average transparency regarding access-related practices. Novo Nordisk publicly discloses its policy positions on access-related topics (e.g., it publicly supports the WHO’s Action Plan for Prevention and Control of NCDs). It is one of the few companies in scope to have a policy that forbids political contributions. It publicly discloses its membership and financial support of patient groups in countries in scope. It includes guidance for responsible interactions with stakeholders in its business ethics code of conduct. It does not, however, publicly disclose its policy approach to payments made to healthcare professionals in countries in scope.

R&D commitment has limited public health rationale. Novo Nordisk has made a specific commitment to R&D for diabetes, a disease in scope, but this is not publicly available. Its R&D strategy for low- and middle-income countries lacks an evidence-based public health rationale including internal assessments and calls for action from external sources like WHO. It lacks time-bound strategies for completing R&D projects for diseases in scope. Novo Nordisk has the smallest pipeline in the Index with 10 projects. Novo Nordisk is active in R&D for diabetes, for which a globally accepted priority list does not exist.

Access provisions in place for 50% (2/4) of late-stage candidates. Novo Nordisk does not have a clear process in place to develop access plans during R&D. While Novo Nordisk considers access for all insulin products at some point, it is unclear whether or not this takes place during the clinical development stage. To date, Novo Nordisk has project-specific access provisions in place for two of its late-stage R&D projects, both of which have received market approval. Neither of these are being conducted in partnership.

Public policy to ensure post-trial access; commits to registering trialed products. Novo Nordisk has a publicly available policy for ensuring post-trial access to treatments for clinical trial participants. The policy is aligned with the standards set in the Declaration of Helsinki. Once a product is approved, Novo Nordisk commits to registering it in all countries where clinical trials for the product have taken place.