Policies & Disclosures
AbbVie is committed to being fully transparent and compliant with our policies and disclosures.
AbbVie believes in being a socially responsible company and doing what is right, not just by our customers, but by the world in which we live. AbbVie is committed to safe and fair working conditions, beyond our employees and the stores in which our products are sold, but also extending to the partners in our supply chain. AbbVie has a global policy against trafficking and slavery in supply chains. AbbVie engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. The verification is conducted by AbbVie employees in AbbVie Purchasing and Supplier Management. Additionally, AbbVie or a third party that is independent of supply chain management conducts audits of suppliers (usually announced ahead of time) to evaluate supplier compliance with company standards for trafficking and slavery.
AbbVie’s Code of Business Conduct sets forth our commitment to conduct our business with the highest ethical standards and comply with all laws and regulations. AbbVie employees worldwide certify annually on AbbVie’s Code of Business Conduct. AbbVie expects its business partners, such as contract workers, vendors, suppliers and consultants, to adhere to ethical behavior consistent with the spirit of AbbVie’s Code of Business Conduct and to all applicable laws and regulations when working on behalf of AbbVie.
AbbVie’s Supplier Code of Conduct states our expectations to suppliers conducting business with AbbVie that they are prohibited from engaging in illegal behavior, including human trafficking and slavery. AbbVie requires direct suppliers to certify that materials incorporated into AbbVie’s products comply with local and national laws regarding slavery and human trafficking of the country or countries in which they are doing business. Certifications are also obtained from suppliers that they comply with standards as outlined in our Supplier Code of Conduct. AbbVie will maintain internal accountability standards and procedures for both employees and contractors failing to meet company standards regarding slavery and trafficking.
Employees and contractors assigned to AbbVie who fail to abide by AbbVie’s Code of Business Conduct may be subject to reprimand or other adverse consequences, up to and including termination of employment or assignment. AbbVie provides training to its employees and management who have direct responsibility for supply chain management, regarding human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.
AbbVie’s ethics and compliance program (the “Program”) reflects our commitment to compliance with the laws and regulations applicable to our business, including the California Health and Safety Code §§119400-119402 (the “California Act”). Interested parties may view the Program online or may also call 800-254-0462 for a copy of any of the Program materials.
In accordance with the California Act, AbbVie has established a specific annual dollar limit of $1,000, which applies to promotional materials, items and activities provided by an employee of AbbVie to covered recipients in California. In addition, the following expenses are excluded from the limit: expenses of a de minimis value (i.e., with a value of $10 or less), expenses that are directly associated with payments statutorily excluded from the limit (e.g., meals for consultants), items provided to health care professionals that are ultimately intended for patients or consumers, fellowships, receptions at third-party educational or professional meetings, and sales aids. To the best of its knowledge, AbbVie declares that as of June 30, 2016, it is in all material respects in compliance with the requirements of the California Act.
AbbVie collects information, including personally identifying information, relating to customers, medical and health care professionals, industry experts and opinion leaders, consumers, suppliers, service providers, business partners and vendors with whom AbbVie has a business or commercial relationship.
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Our Guiding Principles for Working with Patient Groups
Our mission is to have a remarkable impact on patients’ lives
We partner with patient groups at the highest level of transparency and integrity. We’ve established these principles to ensure a common understanding of the way we work with patient groups
The independence of patient groups will not be compromised. AbbVie encourages patient groups to maintain relationships with a wide range of organizations and companies.
All support will be disclosed according to relevant laws and patient groups will recognize company support through locally appropriate means. Both AbbVie and patient groups will have final approval on all public uses of their respective name, logo and identifying symbols.
Trust and mutual respect
Through a mutual and open understanding of each other’s policies, objectives and working practices, AbbVie will demonstrate respect for our partners as we each work toward common desired outcomes. When providing information on marketed and investigational medicines, AbbVie will do so in compliance with applicable local laws, regulations, policies and procedures.
Our Corporate Political Participation Policies
AbbVie’s public policy engagement is guided by the following principles:
- AbbVie is committed to transparency and is guided by our Code of Business Conduct in all public policy engagement.
- AbbVie pursues activities that shape policies to benefit patients, with a focus on improving patient access to new medical advances.
Our Federal Government Affairs office in Washington, D.C. is responsible for advocacy activities with the U.S. Congress and the federal government. Advocacy at the U.S. state level is managed by our State Government Affairs function. AbbVie also hires outside firms that can provide expertise on our key policy issues. AbbVie does not currently make direct expenditures for US federal and state grassroots lobbying communications to the general public. Additionally, AbbVie does not currently contribute funds intended for use in elections to 501(c)(4) organizations but, should such a contribution be made in the future, it would be listed with AbbVie’s other corporate political contributions.
In the United States, in compliance with the Lobbying Disclosure Act, AbbVie will file a quarterly report that includes: (i) total federal lobbying expenditures, (ii) the name of the specific piece of legislation or subject that was the topic of communication, (iii) disclosure of AbbVie individuals who lobbied on behalf of AbbVie, and (iv) identification of the legislative body or executive branch that was contacted. This report incorporates expenses associated with lobbying the federal government, including our Federal Government Affairs office and the portion of trade association dues associated with federal lobbying. We file similar publicly-available lobbying reports with states, as required by law, available here.
Internationally, the AbbVie Government Affairs team supports our regional leaders to frame government agreements and contribute to policy debate. In addition to direct advocacy, AbbVie employees around the world play leadership roles in national and regional trade associations, which are listed here.
AbbVie participates in the political process by contributing to U.S. state and local candidates and political organizations. We support candidates and organizations that understand how government actions can affect patients’ access to medical advances and that will work to promote an environment that fosters continued medical progress.
Contributions to office holders and candidates are bipartisan and based on several criteria: policy positions that reflect AbbVie’s interests; representation of geographic areas where AbbVie employees and facilities are located; relevant legislative committee assignments; ability to be elected; and need for financial assistance. The private political preferences of AbbVie’s executives do not play a role in how corporate political funds are spent.
The Executive Vice President, External Affairs, and the Vice President, Government Affairs, each review and approve all corporate political contributions at the recommendation of AbbVie’s Government Affairs function to ensure these contributions are consistent with the company’s guidelines and in accordance with applicable laws as required by the Corporate Political Contributions Policy. The Public Policy Committee of the AbbVie Board of Directors reviews the Corporate Political Contributions Policy every three years or more frequently and is periodically briefed on the corporate contributions made by AbbVie.
When available, AbbVie will provide links to AbbVie’s corporate contributions to political candidates, political parties, political committees, ballot measure committees, and organizations operating under 26 USC Sec. 527 of the Internal Revenue Code. AbbVie’s corporate political contribution reports are updated every six months and are archived for reference.
Our Membership in Trade Associations
AbbVie is a member of trade associations and other membership organizations that are aligned with our business objectives. In the interest of transparency, the trade associations and membership organizations to which AbbVie provides $50,000 or more in annual membership support may be found here. AbbVie also posts a list of trade associations around the world where an AbbVie employee serves on the organization’s board of directors, which are listed here. The Public Policy Committee of the AbbVie Board of Directors also reviews these memberships.