Conflict of Interest

Personal interests must not unduly influence our professional judgment

A conflict of interest exists when an employee’s personal interests are inconsistent with those of Roche and create conflicting loyalties. As Roche employees we must avoid situations where our personal interests conflict, or appear to conflict, with the interests of Roche.

Activities of relatives and close associates can cause conflicts of interest. We should not take part in, appear to take part in or exert influence on any decision that may put our own interest in conflict with the best interest of Roche.

We should not unduly use our position at Roche for personal benefit or to benefit relatives or close associates. We must carefully consider the potential conflict of interest prior to the acceptance of secondary employment.

Professional engagements outside of Roche, including third-party board memberships, can result in conflicts of interest. Therefore, employees may accept a board membership in a third-party company, commercial entity or scientific advisory board only upon obtaining the prior approval of the relevant Roche executive in the organisation as defined in the Roche Directive on Employees Holding Board Memberships. No prior approval is required for board memberships of charitable, not-for-profit and non-commercial organisations (e.g. sports clubs, charities).

Many actual or potential conflicts of interest can be resolved in an acceptable way for both the individual and the company. In case of a conflict of interest, the employee concerned should immediately inform his/her Line Manager in order to find an appropriate solution.

Perception matters: Roche employees must not only avoid actual conflicts of interest, but also situations where an outsider might assume a conflict of interest situation that the employee might not intend or be aware of.

We are all expected to:
  • Avoid situations in which our personal interests conflict with those of Roche.
  • Not unduly use our position within Roche for personal benefit, the benefit of relatives or close associates.
  • Immediately inform our Line Manager about any actual or potential conflict of interest in order to find an appropriate solution.
  • Inform our Line Manager as soon as we consider serving on the board of a third-party company, commercial entity or scientific advisory board.
Questions & Answers

I am not sure whether a specific ­situation poses a conflict of interest. What should I do?

In case of doubt, immediately inform your Line Manager in order to find an appropriate solution.

My wife works as a manager for a supplier that is competing for a Roche contract. I can influence the selection process. What am I expected to do?

There is an obvious conflict of interest because of your wife’s position. You need to disclose this conflict of interest to your Line Manager and recuse yourself from the decision. He/she will decide whether the supplier your wife works for is in the best interest of Roche. If so, Roche may choose the supplier, despite the fact that your interests are linked.

A friend has just founded a biotech company and wants me to be on the board of directors. What should I do?

As there might be conflicting interests, you need to inform your Line Manager. A Roche employee who wants to serve on the board of a third-party company needs prior written approval from the relevant Roche executive in the organisation (depending on the position, either the Chairman of the Board, the Chief Executive Officer or a Chief Executive Committee Member).

I am a Line Manager and asked whether my daughter can be hired in my team. Is that a conflict of interest?

As a general rule, to avoid the perception of a conflict of interest, employees who are closely related should not work in the same vertical reporting line.

Further Informations

Further information and guidance can be found on the Roche Internet and Intranet. For specific information consult the Roche Directive on Employees Holding Board Memberships.

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