2 of
9
HSE POLICY RULES & PRINCIPLES
Our Commitment
We strive for sustainability
Principles – Our company culture considers protecting the health and safety of
and Rules associates, neighbors, and others affected by our business activities and
protecting the environment to be core values that are treated with equal
importance with our other key business objectives.
– While Management is responsible for implementing and maintaining good
health, safety and environmental practices and leading by example (e.g.
by demonstrating safe, healthy and environmentally responsible
behavior), associates need to understand and respond to HSE matters
with equal importance to other key business objectives. Associates are
expected to perform their duties at all times with a sense of social
responsibility.
We care about the health and for the safety of our associates
Principles – We promote programs to maintain and improve the health and well-being
and Rules of our associates, including, but not limited to, providing tobacco-free
worksites worldwide where legally possible.
– Associates are encouraged to take advantage of voluntary health
programs and to adopt healthy behavior, such as:
committing to exercising regularly
adding additional movement into daily routines
making healthy food choices
participating in health screenings
where available taking advantage of employee assistance and
return-to- work programs.
– Management is expected to support associates in their efforts to lead
a healthy lifestyle.
– We provide our associates with safe working conditions, and strive to
protect them from potential health hazards and injuries. A risk
assessment such as a Process Risk Analysis or Workplace Health Risk
Assessment must be carried out before any potentially hazardous work is
conducted.
– Management is responsible for facilitating risk assessments and
developing protective measures in cooperation with the associates.
Associates must familiarize themselves with local safety requirements
and respect them.
Examples are:
wearing adequate personal protective equipment, when required
respecting safety warning signs and alarms
taking part in training and observation programs e.g. mandatory
site safety training, driver safety training, and behavior based
safety program
reporting unsafe acts, conditions and safety risks.
– Associates are expected to look out for their fellow colleagues and make
3 of
9
them aware of any unsafe behavior.
4 of
9
We care for the environment
Principles – We strive to use natural resources responsibly and to minimize the
and Rules environmental impact of our activities as well as the impact of our
products over their entire life cycle. This includes maximizing energy
efficiency in our operations as part of our overall climate change goals, as
well as applying sustainable packaging and green chemistry where
feasible in our research, development and manufacturing activities.
– Associates should do their best to minimize their environmental footprint
in daily work, including applying the hierarchy of waste prevention
measures (avoid, reduce, recycle and reuse of all materials). Examples
include:
Efficient use of energy
Associates should always consider the most efficient use of energy
and seek opportunities to reduce energy consumption at their
workplaces. This includes switching off lights and office/laboratory
equipment when not in use.
Quality and facility managers should consider the efficient use of
energy when establishing and managing clean room and other
room condition set points (i.e. temperature, humidity and air
change rates) within the acceptable ranges based on regulatory
or compliance standards.
Projects are reviewed for energy efficiency and use of renewable
energy. Preference is given to investment projects improving
energy efficiency with payback over the life-time.
Reduction of greenhouse gas emissions
Associates should whenever possible minimize travel and choose
video or teleconferencing options when available and acceptable
by the business.
Sales associates should choose fuel-efficient cars and drive them
safely and eco-efficiently to save fuel and minimize CO2 emissions.
Recycling or minimization of waste
Associates should avoid creating waste and use recycling options
wherever local recycling schemes are in place. They should
consider the environment before printing e-mails, e-mail
attachments or other working documents.
Packaging designers should consider simplified or smaller size
packages, as well as environmentally benign materials.
Process developers should incorporate techniques to reduce
and recycle solvents.
Production associates should seek opportunities to reduce
intermediates and active substances in waste water discharges.
Efficient use of water
Associates should always consider the best use of water
and identify possibilities to reduce water usage at the
workplace.
5 of
9
We consider HSE implications in the development of products and technologies
Principles – Associates are expected to follow a clear process, which includes state-
and Rules of-the-art HSE risk analysis and impact assessments as relevant to
ensure the benefits outweigh any residual risks to our business
activities, processes, patients and the environment.
– Associates should ensure that HSE considerations are integrated into
product and process development, procurement, manufacturing, and in
capital projects at an early stage.
– Associates should include green chemistry in product development
processes and integrate sustainable packaging into packaging design
processes.
– We engage in scientific peer review, and consider the benefits
and risks of innovation in a structured, scientific and transparent
manner.
We build a network of responsible business partners
Principle – Third Party suppliers are expected to meet the HSE expectations in
s and
the Novartis Supplier Code, which is based on international standards
Rules
and accepted good practices where no standards exist.
Compliance, Continual Improvement and Communication
We comply with local laws and regulations, and conform to internal requirements
Principle – Management establishes Novartis HSE Guidelines, and regularly
s and conducts audits and management system reviews to ensure
Rules
conformance with these Guidelines as well as compliance with
applicable local laws and regulations.
– Sites are encouraged to be certified according to recognized SAIPL (e.g.
ISO14001 and OHSAS18001).
– Associates participate in industry networks to exchange best practices.
We strive for continual improvement in our HSE management systems and performance
Principle – Management sets annual objectives and targets, regularly measures
s and performance against them, and associates are expected to take early
Rules
action if deviations occur. Associates are committed to honest reporting
of HSE key performance indicators.
– We draw lessons learned from accidents and events, and we use them to
raise and improve our standards and communicate these in order to
prevent recurrence.
– Associates assess and mitigate HSE risks related to new products,
processes and technologies to ensure their benefits outweigh inherent
risks. These assessments are periodically reviewed in the light of new
concerns or evidence, and include external benchmarking with
relevant industry standards.
We educate and engage with associates to enable active participation in HSE efforts
Principle – HSE competence is ensured through appropriate recruitment, training
s and
and development. Associates are responsible for ensuring their
Rules
commitment and participation. They also commit to understanding
6 of
9
their HSE accountabilities and responsibilities and to carry them out to
the best of their abilities.
– Management is expected to take seriously any HSE related concerns that
are raised in order to improve our HSE performance.
7 of
9
We communicate transparently
and Rules – We openly communicates HSE results internally and externally, e.g. on
Novartis web and in the Novartis Annual Report. We report our HSE
performance transparently according to best-in-class international
reporting initiatives. Emphasis is placed on recognizing and addressing
any community and stakeholder concerns
about HSE matters.
Definitions
– Health, Safety and Environment (HSE) deals with occupational health,
occupational safety and environmental protection, including, but not
limited to, health promotion and protection, biosafety, process safety,
chemical safety, fire safety and transportation safety, reduction of
emissions to air and water, minimization of waste and the conservation
of natural resources, water and energy.
– Associates referred to in this Policy are all persons who work on Novartis
premises, including third party personnel, and Novartis associates
working outside Novartis premises e.g. sales representatives.
References
– Corporate HSE Guidelines and Guidance Notes, including
supporting tools
– SAIPL Procurement Policy
– SAIPL Supplier Code
8 of
9
COMPANY AUTH. & STAMP.
HEAD OF MANAGMENT
2. Implementation
2.1 Training
Associates are expected to familiarize themselves with this Policy and
participate in HSE training sessions which are held periodically at their
locations.
2.2 Reporting Potential Misconduct/Non-Retaliation
Associates are expected to strictly observe relevant laws and regulations, as
well as the Guidelines and procedures applicable to Novartis. Any associate
who learns of a potential violation of applicable laws or this Policy is required
to report their suspicion promptly in accordance with the section of the
Novartis Code of Conduct entitled 'How to report potential misconduct'.
Anyone who reports a possible violation of applicable laws or this Policy
will be protected from retaliation in any form.
2.3 Breach of this Policy
Breaches of obligations contained in this Policy will not be tolerated and
can lead to disciplinary and other actions up to and including termination
of employment.
2.4 Exceptions
There are no exceptions granted to this Policy. If there are changes in the
state-of-the- art in any field of HSE that would make a change of the Policy
necessary, Corporate HSE will facilitate such a change.
2.5 Implementation
It is the responsibility of every Novartis manager to implement this Policy
within his or her area of functional responsibility, to lead by example,
demonstrating safe, healthy and environmentally responsible behavior, and
to provide guidance to associates reporting to him or her.
Management ensures adequate and appropriate resources are provided to
comply with this Policy.
2.6 Monitoring
Aspects of HSE performance are reported monthly using a global data management
system; these are monitored globally by Division and Corporate HSE.
Furthermore divisional quarterly HSE reviews and corporate annual HSE reviews are
carried out by the HSE Management.
Locations are audited periodically according to their HSE risk profile. Audit results
are reported to the Novartis HSE Steering Committee, with summaries to the
9 of
9