AbbVie Inc. and its affiliated companies (collectively,
"AbbVie" or “we”), have implemented a Code of Business
Conduct reflecting AbbVie’s commitment to honesty, fairness and
integrity. To ensure compliance with the Code of Business Conduct and
to assist AbbVie in addressing its governance, internal audit and
legal obligations, AbbVie has implemented the non-mandatory Ethics and
Compliance Helpline (the “Helpline”) to allow employees, vendors,
suppliers, business partners and those of its subsidiaries,
(“Reporters”) to report violations or concerns in particular related
to anti-bribery, auditing, accounting, financial matters, and/or
anti-trust and competition law issues.
This Helpline Privacy Notice (“Privacy Notice”) explains how AbbVie
handles personal data that it collects and receives from Reporters
through Helpline websites and phone interactions that refer to this
Use of the Helpline is entirely voluntary. You are encouraged to
report possible violations directly to your supervisor or manager, or
to a representative of the human resources, legal or the office of
ethics and compliance, depending on the nature of the possible
violation. If you feel that you are unable to do so, you may use the
Helpline to make your report.
The Helpline is an online reporting system that allows you to report
suspected violations of law or company policies, as well as other
concerns you may have, to AbbVie. In certain countries, AbbVie may
only accept reports through the Helpline that relate to financial,
accounting, auditing, bribery, competition law, discrimination and
harassment and environment, health, hygiene, and safety matters. If
your concern pertains to a matter that, under local law, may not be
accepted by AbbVie through the Helpline, you will need to contact your
supervisor or local management or a representative of the human
resources, legal or the office of ethics and compliance to report the matter.
Please be aware that the information you supply about yourself, your
colleagues, or any aspect of the company’s operations may result in
decisions that affect others. Therefore, we ask that you only provide
information that you believe is true. You will not be subject to
retaliation from AbbVie for any report of a suspected violation that
is made in good faith, even if it later turns out to be factually
incorrect. Please be aware, however, that knowingly providing false or
misleading information may be subject to sanctions.
The Helpline captures the following personal data that you provide,
or someone else may provide, when a report is made: (i) your name and
contact details (unless you report anonymously) and whether you are
employed by AbbVie; (ii) the name and other personal data of the
persons named in the report if provided (i.e.: description of
functions and contact details); and (iii) a description of the alleged
misconduct as well as a description of the circumstances of the
incident, this description must be factual and have a direct and
immediate link to the incident.
Note that depending upon the laws of the country in which you are
residing, the report may not be made anonymously; however, your
personal data will be used and disclosed only as described in this
Your personal data will be used and disclosed for the purpose of
processing and investigating the report provided to the Helpline, for
the administration and monitoring of the Helpline, and for conducting
internal investigations regarding compliance with law and AbbVie
policies and procedures.
AbbVie may need to disclose your personal data in order to comply
with a legal obligation or demand. In such instances, we will take
measures to protect your personal data to the extent possible. We also
reserve the right to use personal data to investigate and prosecute
users who violate our rules or who engage in behavior that is illegal
or harmful to others or to others’ property.
AbbVie will not process personal data for any purpose incompatible
with the purposes outlined in this section, unless it is required or
authorized by law or as authorized by you. When processing personal
data for these purposes, AbbVie’s legal basis is its legitimate
interests in protecting its employees, property and data and to ensure
compliance with applicable law and its internal policies.
AbbVie will not keep personal data longer than necessary to
investigate the report provided to the Helpline, or otherwise as
necessary to address AbbVie’s legitimate compliance concerns. Personal
data which is provided by the Reporter but doesn’t fall into the
purposes of the Helpline is deleted or anonymised without delay.
Personal data may be accessed, processed and used by relevant
personnel of AbbVie, including human resources, finance, internal
audit, legal, the office of ethics and compliance, management, AbbVie
external advisors (e.g. legal advisors; audit firms).
AbbVie has relationships with vendors that help AbbVie operate and
administer the Helpline, and for whom it may be necessary to have
access to your personal data in the course of providing services to
AbbVie. AbbVie will not authorize Helpline vendors to use your
personal data for any purpose that is not related to AbbVie’s business
operations, and AbbVie requires its vendors to handle your Personal
Data collected through the Helpline in accordance with appropriate
contractual privacy and security provisions and this Privacy
Personal Data may be transferred to AbbVie Inc., in the United
States, or other AbbVie affiliates, territories that may not provide a
level of protection to personal data equivalent to that provided by
your home country. Personal data transfers to AbbVie Inc. and among
AbbVie affiliates are governed by the AbbVie Inter-affiliate Data
Transfer Agreement, which are based on the EU model contract for data
transfers to controllers and covers all personal data transfers
between AbbVie affiliates worldwide to ensure the adequate protection
of your personal data. A copy can be obtained by sending an email to
Any transfers of personal data from the EU to third parties outside
the EU will be done in compliance with the international data transfer
restrictions that apply under EU data protection laws, including,
where appropriate, through the use of EU model contracts for data
transfers to processors.
Personal data provided in a report may also be disclosed to the
police and/or other enforcement, regulatory or judicial
AbbVie will promptly notify any person who is the subject of a report
to the Helpline except where notice needs to be delayed to ensure the
integrity of the investigation and preservation of relevant information.
With some exceptions, the subject of the report may access
information concerning the report (with the exception of the identity
of the Reporter) and request correction of personal data that is
inaccurate or incomplete in accordance with applicable law. Similarly,
with some exceptions, Reporters may also access information about the
report and request corrections of their personal data in accordance
with applicable law.
You may contact AbbVie at any time if you have questions about this
Privacy Notice or the personal data we collect about you. Please
submit your inquiry at https://www.abbvie.com/privacy-inquiry.html.
We will respond to all reasonable requests in a timely manner and may
need to further confirm your identity in order to process certain
requests. You can also reach out to AbbVie’s Privacy Office and Data
Protection Officer by sending an email to firstname.lastname@example.org or
sending a letter to: 1 North Waukegan Road, North Chicago, IL 60064
(attention: Privacy Office).
Under applicable data protection law, you may be entitled to request
access to and/or rectify, block, or delete your personal data,
transmission to another controller or object to any use of personal
data. When AbbVie’s legal basis is to ensure compliance with
applicable law and its internal policies, you don’t have the right to
object to any use of personal data. If AbbVie will not be able to
provide the requested information or make the change you request, you
will be provided with reasons for such decision. Under local law you
are also entitled to lodge a complaint with your local data protection
authority. Please submit your
privacy inquiries here.
AbbVie has implemented appropriate technical and organizational
security measures to safeguard personal data. However, there is always
some risk that an unauthorized third party could intercept an Internet
transmission, or that someone will find a way to thwart our security systems.
Abbvie will only use Personal Data in the manner described in the
Privacy Notice in effect when the information was collected. However,
unless required by law, we reserve the right to change the terms of
this Privacy Notice at any time. Any changes to this Privacy Notice
will be reflected on this page with a new effective date. AbbVie
encourages you to review this Privacy Notice regularly for any
changes. Any Personal Data collected will be handled in accordance
with the currently-posted Privacy Notice.
In particular in the European Union, reports may be limited in
topics, generally to concerns about accounting, auditing, bribery,
competition law, discrimination and harassment and environment,
health, hygiene, and safety matters. Further, some countries restrict
reports such that only employees in key or management functions may be
the subject of a report.
Any issues or concerns relating to topics not permitted by law to be
reported via the Helpline should be reported directly to your Manager
or Supervisor or a representative of the Human Resources, Legal or
Corporate Compliance Departments as appropriate for the subject matter
of the possible violation. In some countries, anonymous reports may
not be permitted under the law except under extremely restrictive circumstances.