AstraZeneca Annual Report and Form 20-F Information 2011

ComplianceWe ensure a culture of ethicsand integrityOur task is to ensure thatwe operate in step withthe evolving complianceenvironment globally and ina way that is consistent withour values”Katarina AgeborgChief Compliance OfficerWe work to promote best practice in compliancewithin AstraZeneca in the rapidly changingexternal environment in which we operate. Thisis critical to ensuring the trust of our stakeholdersand the patients we serve.Our Global Compliance function has been established to drive andembed a culture of ethics and integrity within our organisation. Theaddition of Global Compliance to the SET reflects the growingimportance of compliance to our business operations.Our key compliance priorities include:> focusing our efforts on important compliance risk areas> communicating clear policies to employees> improving compliance behaviours through effective trainingand support> ensuring employees can raise concerns and that those concernswill be properly addressed> ensuring fair and objective investigations of possible policy breaches> monitoring and auditing compliance with policies and workingwith GIA> providing key stakeholders with assurance and effective reportingof material issues.AstraZeneca Annual Report and Form 20-F Information 2011These priorities are closely aligned to the Group’s strategic prioritiesand reflect our drive to strengthen our efforts for oversight at all levelsof our business, including risk management relating to third parties,anti-bribery and anti-corruption. GIA and Global Compliance workclosely with one another and both separately provide assurancereporting to the Audit Committee. Our Global Compliance functionalso works together with a range of specialist compliance functionsthroughout our organisation to ensure ongoing legal and regulatorycompliance. When a potential compliance breach is identified, aninternal investigation is undertaken by appropriate staff from ourGlobal Compliance, Human Resources and/or Legal teams. Whenappropriate, external advisers are engaged to conduct and/or adviseon investigations. Should the investigation conclude that an actualcompliance breach has occurred, management, in consultationwith our Legal function will consider whether the Company needsto make a disclosure and/or to report the findings to a regulatory orgovernmental authority. More information on GIA and our overall riskmanagement and control framework can be found in the CorporateGovernance Report from page 103.Code of ConductOur Code of Conduct (the Code) is at the core of our complianceprogramme and applies to all our employees at every level and inevery country in which we operate. It has been translated into over40 languages and each employee has a copy in his/her local language.It provides clear direction as to how our commitment to honesty andintegrity is to be translated into consistent actions across all areasof the business. Every employee receives training on the Code andcompliance with it is mandatory. Similarly, every employee is requiredto comply with local laws and regulations, as well as applicable nationaland international codes. We always seek to operate at the highest ofthese various standards, whether this is our Code, national legislationor other applicable codes. The Code is regularly reviewed and updatedto take account of our changing legal and regulatory obligations.The Code includes information on how to report possible violationsof the Code, including through the AZethics telephone lines and theglobal website, AZethics.com. Anyone who raises a possible breachin good faith is fully supported by management. We take all allegedcompliance breaches and concerns extremely seriously andinvestigate and report them to the Audit Committee, as appropriate.In 2011, 222 reports of alleged compliance breaches or other ethicalconcerns were made via telephone, the AZethics.com website, or theGlobal Compliance email or postal addresses described in the Code.In 2010, the number of reports through equivalent channels was 368.This decrease is in the context of a significant increase in managementself-reporting of compliance incidents, which can be seen as anindication that employees are more comfortable in raising their concernswith line managers, local Human Resources, Legal or Compliance,as recommended in the Code and reinforced in the 2011 annualCode training.As with the Code, our global policies apply to all members of ourGroup. They provide clear and comprehensive guidance, in plainlanguage, to all managers and employees as to their accountabilitiesin key ethical, compliance and corporate responsibility risk areas.We report on the operation of our Global Policy on ExternalInteractions on page 51.Delivering our strategy Compliance 43Business Review