Integrity, excellence and respect

Ethical Business

For more than 140 years, we have approached our company’s business with a deep sense of responsibility to those we serve—patients, physicians and other health care providers, shareholders, suppliers, business partners, employees, and the communities in which we operate. Our actions are grounded in our core company values of integrity, excellence, and respect for people.

As a leading pharmaceutical company, we look for answers to some of the world’s most urgent medical needs. We discover and develop products through rigorous testing and in accordance with the highest scientific and ethical standards. We strive to create products that fulfill the clinical promise of their Lilly label.

At Lilly, how we do business is as important as what we do. We strive to be a leader in corporate responsibility. We demonstrate our values through responsible business practices that reflect our commitments to strong governance principles; transparency; patient, customer, and employee privacy; ethical product promotion; and stakeholder engagement. Our participation in the public policy process also demonstrates our values and affects how we do business.

Business Practices

Our three core values – Integrity, Excellence, and Respect for People – guide Eli Lilly and Company in all that we do. As the stewards of our company culture and reputation, HOW we do business is an important as WHAT we do. Being compliant and operating within ethical boundaries and with honesty and transparency is critical for us to:

  • Earn and retain the trust of our customers,
  • Fulfill our vision of providing improved outcomes for individual patients, and
  • Maintain the privilege of operating in the highly regulated pharmaceutical industry.

Ethics & Compliance Program

Lilly is committed to the highest standards of corporate conduct in all of our business dealings globally. Lilly maintains an effective ethics and compliance program designed to meet external requirements, guided by our core values and code of business conduct, The Red Book. It is our expectation that Lilly employees will comply with The Red Book and the policies that have been established in support of that code. We periodically review and enhance the ethics and compliance program to meet changing business needs and external requirements.

Lilly’s ethics and compliance program is a central component of how business is conducted and has oversight from the board of directors’ Public Policy and Compliance Committee. The fundamental elements of our ethics and compliance program are outlined below:

Oversight

Chief ethics and compliance officer: Lilly has appointed a Chief Ethics and Compliance Officer to lead ethics and compliance activities. The Chief Ethics and Compliance Officer has the ability to lead change within the organization and is responsible for developing, operating, and monitoring the compliance program. The Chief Ethics and Compliance Officer reports directly to the Lilly Chief Executive Officer and to the Public Policy and Compliance Committee of the Board of Directors.

Compliance and Enterprise Risk Management Committee: Lilly has established a Compliance and Enterprise Risk Management Committee to advise the Chief Ethics and Compliance Officer and to assist in the implementation of the ethics and compliance program. The committee is chaired by the Chief Ethics and Compliance Officer and submits reports on the state of Lilly’s ethics and compliance program to the Public Policy and Compliance Committee of the company Board of Directors multiple times per year.

Written Standards

Lilly’s Code of Business Conduct, The Red Book, is the statement of principles that guide the company’s operations. The Red Book outlines Lilly’s core values as well as the expectation and framework for ethical and compliant behavior by those who work for Lilly or on behalf of the company. For more information, download The Red Book.

The Red Book directs management and employees of the company globally to act in accordance with laws, other legal requirements, and applicable company policies. Lilly also provides for its employees more detailed policies, standards and procedures that establish expectations for ethical and compliant behavior. The Red Book includes references to company policies that apply globally, as well as examples to illustrate application of The Red Book principles.

Education and Training

A critical element of Lilly’s ethics and compliance program is the continuing training and education of its employees on application of the core Lilly values, and individual obligations under applicable legal requirements and company policies. Lilly trains all its employees on The Red Book, including its content and application to daily activities. Lilly also provides targeted training in key risk areas to those employees whose job functions are affected by those risk areas.

Internal Lines of Communication

Lilly is committed to fostering dialogue between management and employees through multiple channels. Supervisors are expected to maintain an environment that promotes open communication.

Lilly’s goal is that employees know where to turn when they are seeking answers to questions or reporting potential instances of fraud and abuse, or other potential violations of law, regulations, or company policies. Employees may submit reports through their management, or to human resources, a company attorney, the ethics and compliance department, the general auditor, or the chief ethics and compliance officer.

Lilly does not tolerate retaliation by any individual against another for good faith reports of potential violations of law, regulations, or company policies. See The Red Book for further information.

Auditing and Monitoring

Lilly’s ethics and compliance program includes ongoing efforts to assess, evaluate, monitor, and audit compliance with the company’s ethics and compliance policies and procedures. The nature, extent, and frequency of these activities depend on a variety of factors, including new regulatory requirements, changes in business practices, and other considerations.

Auditing, monitoring, and assessment activities are conducted annually, and results are reported to local management and corporate governance committees.

Responding to Potential Violations

Lilly’s ethics and compliance program includes disciplinary principles that set out the consequences to individuals who violate the law, regulations, or company policies. Although each situation is considered on a case-by-case basis, Lilly imposes discipline to address inappropriate conduct and to deter future violations. See The Red Book for further details.

In addition to imposing appropriate disciplinary action, the company also assesses whether a violation may be due in part to gaps in Lilly’s policies, training, business practices, or other controls. If so, the company is committed to implementing corrective measures to enhance its controls to prevent further violations.

Ethics & Compliance Vision

We create trust with customers, stakeholders, and fellow employees when business decisions are made with high integrity. Doing this protects the patients we serve, the company, and our brand and reputation.

Ethics & Compliance Mission

In Ethics and Compliance we drive the integration of high performance with high integrity.

Lilly Ethics and Compliance

REPORT AN ETHICS VIOLATION / CONCERN: If you believe that in the course of doing business we have not met regulations, or even fallen short of our own values, please tell us by calling the Lilly Ethics and Compliance Global Hotline at 1-800-815-2481 or via www.lillyethics.ethicspoint.com. Please note, if you are reporting from outside of the United States, you will be prompted with instructions for submitting a report consistent with local process. For Reporting from Countries with Hotline Reporting Restrictions, please click here. For direct dialing instructions, please click here.

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