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Dr. Britta Lüscher, Director Compliance, Novartis LexisNexis Compliance Solutions Day, München June 2015 Compliance Training - Can you get it right?

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Dr. Britta Lüscher, Director Compliance, Novartis

LexisNexis Compliance Solutions Day, München

June 2015

Compliance Training - Can you get it right?

Agenda

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 2

Who am I?

| HBA career management | Dr. Britta Luescher | 20 March 2012 3

Creativity

Novartis Intro a world-leading healthcare company

2014 USD billion

Net sales: 58.0

Net income: 10.3

R&D investment: 9.9

Key figures

Leading market position

One of 25 largest companies by market capitalization

Among most respected companies globally

Sales by region 2014

Canada/

Latin America

US

Europe Asia/Africa/

Australasia 37%

32%

21%

10%

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 4

Novartis Intro Our organization is poised to lead in these segments

Novartis Institutes for BioMedical Research

(NIBR)

Novartis Business Services

(NBS)

No.2 generic medicines

company worldwide

One of the world’s largest

pharmaceutical companies

No.1 eye care

company worldwide

Alcon Sandoz Novartis Pharmaceuticals

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 5

In 2014 Novartis products

reached more than

1 billion

patients

To be the world's most

respected and successful

healthcare company

Our Vision √

To care and cure

Our Mission √

Novartis Intro Always with a focus on patients

Science-based innovation

Better patient outcomes

Growing areas of healthcare

Our Strategy √

Innovation

Quality

Collaboration

Performance

Courage

Integrity

Our Values √

To be the world's most

respected and successful

healthcare company

Our Vision √

To care and cure

Our Mission √

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 6

Novartis Intro Our achievements are gaining recognition

#2 pharmaceutical

company in Fortune’s

World's Most Admired

Companies

Novartis in top 3 for

11th consecutive year

#4 in the Access to

Medicine Foundation’s

Access to Medicine

Index

Top 100 Global

Innovator

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 7

Novartis Compliance Program

Controls &

reporting

Whistleblower

line & audits

Policy

framework

Objectives

and annual

performance

Blogs

Town halls

Intranet

Training

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 8

Traditionally the objective of

the Compliance Training has

been to establish a legal

defense

World has evolved.

The new priority for compliance

training is building an ethical

culture

New challenges aroused

► “Check-the-box” training is now not

just outmoded but also puts the new

objective at a risk by increasing

employee´s cynicism

► High quality, engaging training must

become the norm (not the exception)

Compliance Training... What for?

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 9

56%

54%

42%

41%

31%

23%

23%

19%

18%

17%

35%

42%

44%

46%

54%

67%

59%

57%

46%

62%

10%

6%

14%

13%

15%

10%

18%

24%

36%

22%

Significant Challenge

Not a Challenge

Moderate Challenge

Limited hours available for training

Measuring Effectiveness

Not enough budget

Difficulty covering all of the topics important to our organization

Training content is growing old/stale

Training not effective at changing attitudes or behavior

Training content is low quality / unengaging

Training content is not relevant to our audience

Difficulty tracking and reporting training completion

Employees respond negatively to training

Data Source: NAVEX Global’s 2014 Ethics and Compliance Training

Benchmark Report

Seat time and budget constraints are considered top challenges

for compliance training nowadays

1

2

3

10

9

8

7

6

5

4

Challenges & concerns

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19%

64%

10% 5% 3%

21%

69%

9% 2% 1%

57%

36%

4% 1% 2%

55% 41%

3% 1% 0% 7%

76%

14% 3% 1%

Median = 2.5 Courses

Median = 2.5 hours Median = 0 hours

Median = 0 Courses Median = 1.5 Courses

6%

69%

13% 8% 5%

Median = 2 hours

Challenges & concerns

Training

Hours (annual)

Training

Courses (annual)

Median for Middle Managers and Non Managers is 2.5 hours / 2.5

courses.

Compliance Training to Third Parties at a risk

0 Courses 1 – 5 Courses 6 – 10 Courses 11 – 15 Courses 16 or more Courses

0 Hours 1 – 5 Hours 6 – 10 Hours 11 – 25 Hours 25 plus Hours

Senior Leaders Middle & Non Managers Third Parties

Data Source: NAVEX Global’s 2014 Ethics and Compliance Training Benchmark Report

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 11

Q1 Q2 Q3 Q4

Max: 4 Short Courses / Refreshers (~10 min each)

Max: 4 Full courses (~20-30 min each)

Code of

Conduct AB

Su

mm

er

Bre

ak

Cu

t O

ff:

No

Ro

llo

uts

Adverse

Events

CoI

1 2 3

4

Onboarding Course for ALL New hires (internals & externals)

2015 Novartis Compliance e-Training Curriculum

Strategic Curriculum Design

We don’t fill our slots just because we have them

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 12

Training Topics

73%

53%

47%

46%

45%

42%

40%

36%

34%

25%

25%

22%

22%

27%

38%

17%

38%

37%

44%

26%

32%

44%

26%

63%

5%

20%

15%

37%

17%

21%

16%

38%

34%

31%

49%

15%

All employees

Course not offered

Some employees

Code of Conduct

Recognizing and reporting misconduct

Information security awareness

Anti-retaliation

Data Privacy

Conflict of Interest

Gifts and Entertainment

Ethical Decision Making

Handling and escalating allegations

Fraud Awareness

Data Source: Benchmarking analysis by CEB (Compliance Executive Board)

“Code of Conduct” and the “Recognizing and reporting

misconduct” are courses most frequently required for all employees

Social Media Use

Anti-Corruption or Anti-Bribery

1

2

Despite the significant

legal & reputational risk

that Anti-Bribery area

poses to an organization, it

is ranked surprisingly low.

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 13

Training Format

71%

68%

57%

48%

47%

45%

45%

36%

33%

31%

29%

26%

15%

11%

7%

6%

2%

Online Training

Live Training

Email

Certification System

Print Resources (e.g. Handbooks)

Intranet

Posters

Informal meetings

Newsletters

Webinars

Manager Discussion Materias

Short Training Vignettes

Wallet Cards

Digitak Resources (e.g. e-books)

Social Media

Direct Mail

Other

Data Source: NAVEX Global’s 2014 Ethics and Compliance Training Benchmark Report

Using wide variety of

formats to reach learners

has proven to be more

effective creating higher

impact and thus delivering

better results

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 14

• Central approach : Capacity and Consistency

Covers huge audience in remote locations and ensures that the message is communicated in a

consistent fashion.

• 24/7 Accessibility

The course can be accessed anytime, anywhere.

• Improved Pedagogy

Gamification enhances learner engagement and improves retention

• Speed, Time and Money Savings

Reduces time away from the workplace & eliminates the need for travel. 1 investment for all your

employees & no training material costs, can be achieved at defined timelines

• Flexible

Gives employees the freedom to learn at their own convenience and at a pace that is right for them.

• Consolidated reporting

Element to establish legal defense and to demonstrate compliance program’s effectiveness

Benefits of e-Training

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 15

• 100% relevant content

• Customized to meet organization´s unique needs

• Reflect your corporate style and philosophies

• Enhances learner engagement (direct relation to their jobs)

• Full Ownership: Full rights to use and edit. Does not need user

licenses

Benefits of bespoke content

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 16

Anti-Bribery

Information

Management

Fair Competition

Conflict of

Interest

2012 2013 2014 2015

Novartis Communications Campaigns Courses and communication are branded

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 17

This approach enables your organization to provide appropriate training across the organization

based on factors such as role, geography and their level of exposure to a particular risk

High risk roles

Job in the crosshair of a particular

risk. Significant impact to the org.

if risk is mishandled

Medium risk roles

Jobs facing the risk on a regular

basis. Moderate impact to the org.

if risk is mishandled

Low risk roles

Low likelihood of the job facing the

risk. Low impact to the org. if the

risk is mishandled

• Frequently repeated training

• Several formats (online, face

to face, campaigns, etc)

• Training refreshed

periodically

• Online training, campaigns

• Regular Education

• Campaigns, email, newsletter

Risk-based approach

Risk-based approach, goes beyond simple „check box‟ compliance by

focusing training efforts to maximize the return on the investment.

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 18

E-Training evolution at Novartis

2012 2013 2014 2015

• Bespoke Novartis courses

• Own content, look & feel

• Use of real cases

• «Action mazes» shorter content for learners selecting compliant answers

• In-course profiling

• Segmentation by Function

• New Hire onboarding: 1st Bundle course

• Real-time reporting (24/7)

• Consistently high completion rates

• First online training for New External Contractors

• Increased use of «interactivity»

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 19

Compliance Training Trends

Increase number of trainings to cover more risk areas that

s are currently uncovered 1

Additional Emphasis on Middle Manager training 2

Collaborative Learning (peer-to-peer, group discussion, problem solving etc.) 3

Training Third Parties 4

Gamification 5

Data Source: Selected trends from NAVEX Global’s 2014 Ethics and Compliance Training Benchmark Report

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 20

Compliance Training Trends (cont.)

Trend ranked n° 1: Increase number of trainings to

cover more risk areas that are currently uncovered

Given the constraints of seat time and budget, for

organization adding courses will mean getting creative

SMART options:

• Risk-based approach

• Blended courses: use different format to reach learns

• Bundled courses: combine several topics in one

• Short courses

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 21

Training Quality

88%

81%

80%

77%

64%

62%

42%

37%

10%

16%

17%

20%

32%

30%

44%

33%

2%

3%

3%

3%

4%

8%

14%

30%

Significant Importance

Not Important

Moderate Importance

Look & Feel, Engaging and Interactive

Fresh and Contemporary Content

Customized Options

Reputation of Vendor and Service

Endorsement of Respected Regulatory Bodies

Training Provider Learning Management System (LMS)

Mobile Enabled

Content Translated into other languages

High-quality training is seen as superior when is credible, fresh and

relevant.

Data Source: NAVEX Global’s 2014 Ethics and Compliance Training Benchmark Report

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 22

Measuring Effectiveness

Ethics and Compliance training is supposed to prevent

problems from happening so... How can one quantify that

which hasn't happened?

While the most common and frequently used method is

measuring completion rates, it only measures successful

training deployment, not effectiveness.

To improve measurements is key that organizations establish a

robust set of KPIs for training programs which can include

completion rates but also other methods like focus groups,

surveys, litigation data, changes in helpline‟s reports etc.

| LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 23

Thank you! | LexisNexis Compliance Solutions Day | München | March 2015 | Business Use Only 24