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4 Keys to a Strong Code of Conduct for Pharmaceutical Companies

Does your code of conduct help prevent internal incidents, compliance lapses and consumer health issues?

Posted by Ann Snook on May 7th, 2021

Is your code of conduct a dry, boring document that makes your employees’ eyes glaze over?

Then it’s time for a rewrite.

Pharmaceutical companies need codes of conduct that show their commitment to an ethical, safe workplace and are easy for employees to understand. Include these four things in your code to reduce your risk of internal incidents and, in turn, prevent fines, penalties and harm to consumers.


Without a guide, employees won't know what behavior is and isn't acceptable.

A strong code of conduct sets the tone for the ethical character of the company, outlines the kinds of behavior the company encourages and prohibits, and give employees guidelines to follow. Download this free code of conduct template to write a document that fits your company’s needs.

Get the Template

1. Encourage Reporting


Safety incidents, ethics and compliance lapses and employee misconduct can put any company at risk. But extra regulations and concerns for consumer safety increase that risk for pharmaceutical companies.

In Pfizer’s Code of Conduct, a section titled “Courage” states: “We value, respect, and review all reports. If you suspect potential misconduct, report it. Potential misconduct includes failing to follow laws, regulations or policies, or failing to live our Values.”

The document also includes a commitment to a zero-tolerance policy towards retaliation to encourage reporting. The section concludes with a table listing departments employees can report to, what situations are appropriate for each and their contact information.

Show employees that reporting their concerns is safe, easy and essential to the success and well-being of themselves, the company and consumers.

Learn more about the benefits of internal hotlines in the video below.

2. Help Employees Make Good Choices


Even with a clear set of rules, employees might not know how to handle tricky situations at work. Whether they’re tempted to cut corners on safety to meet a deadline or are asked to do something unethical by their manager, they need quick references to help them decide what to do.

Glaxo Smith Kline’s code of conduct includes a decision-making flowchart at the beginning of the document. It instructs employees to ask themselves the following questions about a choice:

  • “Is it aligned with our values and expectations?
  • Does it meet regulations and laws?
  • Is it consistent with our policies?
  • Have I assessed all the risks involved?
  • Will this be clearly understood by a colleague?
  • Would I be happy with this if I were a patient or consumer?”


If they answer yes to every question, they should go ahead with their decision. If they answer no to any of them, GSK advises they “think again about what to say or do, talk to your manager, or use the reporting channels to speak up.”

Throughout Johnson & Johnson’s Code of Business Conduct, employees can find real-life workplace dilemmas and what to do in the situation. These explain the practical use for the policies, making employees more likely to understand, remember and follow the rules.


Your code of conduct not only guides employees, but also tells investors, customers and other stakeholders about your company’s values. Learn how to write a successful code in this free webinar.


3. Emphasize Safety


An unsafe work environment puts employees and consumers at risk. Ignoring protocols can lead to an employee injury or illness. A mistake in the lab or during production could put consumers’ lives in danger.

That’s why a strong health and safety section should be included in every pharmaceutical code of conduct.

Johnson & Johnson reminds employees that they should prioritize safety in the workplace by following these instructions:

  • “Promptly report unsafe or hazardous conditions to supervisors and hosts.
  • Comply with all Company policies, standards and procedures relating to workplace health and safety.
  • Comply with all applicable workplace health and safety laws and regulations.”


Link or direct employees to your safety policies and relevant laws for further reference. To make following this part of your code even easier, include an FAQ section that addresses common health and safety situations and dilemmas in your workplace.


RELATED: Why Every Pharmaceutical Company Needs a Hotline


4. Discuss Laws and Regulations


When they’re told to do something, many people automatically wonder (and ask), “why?” When they know the legal and regulatory reasons behind the rules in your code of conduct, employees are more likely to follow them.

Pfizer’s Code explains:

“Our industry is subject to many rules and regulations designed to protect patients and consumers, improve the quality of medicines and healthcare services, and help eliminate fraud and improper influence on medical judgment. We demonstrate our commitment to Excellence by following all laws and regulatory requirements governing our activities, including in the development, manufacturing, distribution, marketing, government contracting, sale, and promotion of our products.”

It goes on to discuss the different types of laws the company is subject to (e.g. anti-corruption, antitrust, insider trading, trade controls) and how employees should follow them.

Explain the regulations your company is subject to and list practical ways to adhere to these. Employees might be confused or overwhelmed trying to interpret laws and regulations, but easy-to-understand do’s and don’t’s, FAQ’s and real-world scenarios help clarify their responsibilities.


RELATED: 18 of the Best Code of Conduct Examples


A strong code of conduct gives your employees behavioral guidelines and helps them make decisions at work. Make sure yours is clear, thorough and in line with your core values to protect employees, consumers and your company.

Ann Snook
Ann Snook

Marketing Writer

Ann is a marketing writer at i-Sight Software. She writes about issues related to investigations of fraud, employee misconduct, corporate security, Title IX, ethics & compliance and more.

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