Policies & Disclosures

Our engagement with the U.S. Federal and State governments

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.
• AbbVie federal and state government affairs representatives participate in annual ethics and legal training on political engagement. 

Furthermore, AbbVie does not;

• provide political contributions in anticipation of, in recognition of, or in return for an official act;
• seek or receive direct or indirect reimbursements for personal political contributions or expenses;
• pressure or coerce fellow employees to make personal political contributions; or,
• reward employees or make employment decisions based in whole or in part on that employee’s personal political contributions.

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 U.S. 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.

The AbbVie Board of Directors’ public policy and sustainability committee exercises oversight of AbbVie’s political expenditures and lobbying activities, as specifically enumerated in the committee’s charter, and which are further governed by the Committee’s approved policy on political contributions.  The public policy and sustainability committee and AbbVie’s senior management review these activities and expenditures on a regular basis.  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.  Our latest federal lobbying disclosure filings can be found on the U.S. Senate Office of Public Records website and the U.S. House of Representatives Office of the Clerk website.  We file similar publicly-available lobbying reports with states, as required by law, available here.

AbbVie advocates on a range of issues in the United States, including:

• Advancing patient access to drug therapy as prescribed by their clinician
• Reducing patient out of pocket costs
• Strong intellectual property protections
• Rewarding innovation

The Senior Vice President, Government Affairs, exercises oversight of all external vendors that lobby on AbbVie’s behalf and periodically updates the Public Policy and Sustainability Committee of the AbbVie Board of Directors regarding AbbVie’s lobbying priorities.

Our report on political contributions

AbbVie participates in the political process by contributing to U.S. federal, 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.  As discussed in more detail below, this support comes via two mechanisms: (1) corporate political contributions direct from AbbVie and (2) political contributions directed from the AbbVie Political Action Committee.

Contributions to office holders and candidates are bipartisan and based on several criteria: policy positions that reflect AbbVie’s interests related to key advocacy priorities; 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 or other employees do not play a role in how corporate political funds are spent.

The Senior Vice President, Government Affairs, reviews and approves 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 and Sustainability 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 political contributions made by AbbVie.  

An internal Political Action Committee (PAC) Board of Directors guides the AbbVie PAC.  The PAC Board is chaired by the Senior Vice President, Government Affairs and is comprised of at least twelve senior leaders representing a broad range of functions within AbbVie.  The AbbVie PAC Board members hold a wide range of experiences and perspectives that inform AbbVie PAC activities.  A direct link to AbbVie’s PAC contributions can be viewed on the Federal Election Commission website here.

Both AbbVie’s PAC and direct corporate political contributions support a wide range of candidates and committees representing both major political parties and independent candidates and committees.  For example, AbbVie’s federal political contributions, which include contributions to re-election committees, leadership political action committees, national political action committees and national political party committees, have historically been evenly split between Democratic and Republican organizations.  Many of the recipients of AbbVie’s political contributions engage on a broad range of issues in the course of their regular work, some of which have a direct impact on AbbVie and the patients AbbVie serves, while others are not directly related to AbbVie or the biopharmaceutical industry.

All AbbVie corporate and AbbVie PAC political contributions are vetted through a rigorous process that includes:

1. AbbVie federal and state Government Affairs representatives vetting candidates and submitting proposals to Government Affairs leadership

2. An internal review to confirm that the contribution meets AbbVie’s giving criteria and is within the approved budget, and to assess the reputational risk of making the contribution

3. An external compliance review to ensure the contribution is permissible in the relevant jurisdiction

4. The Senior Vice President, Government Affairs reviewing and approving each contribution

5. AbbVie Finance confirming financial controls and policies have been complied with for all political contributions.

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.

Jan – Dec 2022 Corporate Political Contributions

Jan – Dec 2021 Corporate Political Contributions

Jan – Dec 2020 Corporate Political Contributions

Jan – Dec 2019 Corporate Political Contributions

Jan – Dec 2018 Corporate Political Contributions

Jan – Dec 2017 Corporate Political Contributions

Jan – Dec 2016 Corporate Political Contributions

Jan – Dec 2015 Corporate Political Contributions

Jan – Dec 2014 Corporate Political Contributions

Jan – Dec 2013 Corporate Political Contributions

Our membership in trade associations

AbbVie belongs to trade associations that represent a broad range of policy issues impacting the company and patients.  AbbVie works with its trade associations to ensure AbbVie’s positions are understood and represented within each trade association.  Given that these trade associations represent numerous and diverse members, AbbVie understands that we may not always agree with every position a trade association takes.  In these circumstances, AbbVie conveys, as appropriate, any concerns through our colleagues who serve on the boards and committees of these associations.  We may recuse ourselves from an activity or initiative when appropriate or when we have a divergent point of view.

Furthermore, AbbVie regularly reviews its trade association memberships on the basis of several factors, including but not limited to congruency on key issues, priorities, initiatives, and overall alignment. After an annual review process in late 2022, AbbVie made the decision to leave select trade associations.  For 2023, the U.S. Chamber of Commerce is the largest trade association lobbying at the federal level to which AbbVie belongs.  AbbVie has assessed our alignment with the U.S. Chamber of Commerce on the key topics critical to AbbVie's business, including intellectual property, access to healthcare, and tax, and is confident that there is alignment between the Chamber’s stated positions and our positions on these issues.

The major U.S. trade associations to which AbbVie provides $25,000 or more in annual membership dues, and which lobby in the U.S. at the federal level 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 and Sustainability Committee of the AbbVie Board of Directors also reviews these memberships.

Our engagement with governments outside the U.S.

AbbVie's global affiliates may participate in the political process in their local jurisdictions where permitted by law. These activities are subject to the laws and public disclosures of the relevant jurisdiction and governing body. Information about AbbVie’s lobbying activities in the European Union can be found here.

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.

Independence

The independence of patient groups will not be compromised. AbbVie encourages patient groups to maintain relationships with a wide range of organizations and companies.

Transparency

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.

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 $2,500, which applies to promotional materials, items and activities provided to covered recipients in California. In addition, the following expenses are excluded from the limit: 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 March 31, 2023, it is in all material respects in compliance with the requirements of the California Act.

AbbVie’s HUMIRA (adalimumab) Sharps Mail-Back Program

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. To learn more, please click here.

At AbbVie, R&D centers around the patient, from understanding disease biology to treatment delivery, clinical trials, and beyond. We combine our experience pioneering scientific breakthroughs, the best ideas in science, and advanced technologies to develop the next generation of medicines.

Each year we spend billions on R&D, enabling us to discover and deliver innovative medicines and products that solve serious health issues and enhance people’s lives today and address the medical challenges of tomorrow.

Intellectual property, in particular patents, is critical to protecting the significant investments that allow AbbVie to solve these serious health issues.  Patents ensure that we are able to recoup investments, not only in the initial creation of a medicine itself, but also in AbbVie’s ongoing investment in that medicine – for example, by studying it in new patient populations and diseases over time, by optimizing the process used to manufacture the medicine, and by improving the formulation of the medicine over time to better meet patient needs.  Patents also allow us to re-invest in developing new medicines, further improving patients’ standard of care over time. 

When AbbVie assesses whether to apply for a patent to cover a certain innovation, we consider many factors.  First, science is at the heart of everything we do at AbbVie, including our decisions related to patents.  AbbVie pursues patents that reflect meaningful innovation and scientific advancements, including those that have the potential to improve the treatment of patients.  Such innovation may improve the safety and efficacy of patient care and the quality and efficiency of AbbVie’s manufacturing processes.  Second, in evaluating intellectual property, we carefully consider the technology, the state of the art, and patent laws of the relevant jurisdiction.  Third, AbbVie considers the value of our public disclosure in advancing science.  Finally, we take into account the size of the underlying investment and the impact on patient access.  We believe considering these factors, and others, can both protect AbbVie’s investments and further patient access to innovative new medicines.

AbbVie has an established history of granting patent licenses under appropriate circumstances, in order to facilitate broader global access to our medicines.  AbbVie’s patient support and assistance programs further demonstrate our commitment to patient access and meeting unmet need.

AbbVie’s intellectual property processes are overseen by AbbVie’s Executive Vice President, General Counsel and Vice President, Intellectual Property and Strategy and R&D.  The Board of Directors also oversees AbbVie’s intellectual property strategy, as well as AbbVie’s approach to patient access. 

AbbVie participates in numerous external collaborations and projects dedicated to furthering the responsible use of intellectual property.  For example, AbbVie is a signatory for IP Principles for Advancing Cures and Therapies (IP PACT) and participates in Pat-INFORMED (Patent Information Initiative for Medicines).