Responsible Marketing Of Medicines

Responsible marketing of prescription medicines is vital to maintaining consumer trust in the pharmaceutical industry and ensuring patients receive the maximum benefits from our products and services. Government regulation and industry codes oversee the marketing of our medicines, vaccines and therapies across key regions where we operate.

CSL recognises that reputation in the marketplace and success as a trusted supplier of biopharmaceuticals relies on ensuring our medicines, vaccines and therapies are honestly represented in our interactions with healthcare professionals, consumers and other customers. Promotional Review Committees, comprising cross-functional members, operate across CSL business units to ensure compliance with all applicable local laws, regulations and accepted industry codes, such as Medicines Australia Code of Conduct (MA Code) and the European Federation of Pharmaceutical Industries and Associations Code for European Union member countries. The committees are responsible for ensuring information on medicines, vaccines and therapy areas is balanced, supported by scientifically valid data and compliant with relevant laws and codes.

All business units, supported by complementary functions, such as Medical Affairs and CSL Legal, have training programs and procedures in place to ensure compliance. When we engage with third parties, such as distributors, CSL requires third parties to comply with all applicable laws and the principles set out in the CRBP. These requirements are enforced by contractual agreements and periodic reviews.

During 2015/16, neither Seqirus Australia nor CSL Behring Australia were found to be in breach of the MA Code. For international operations, CSL (including CSL Behring and Seqirus) was not found to be in breach of any regulation of the US FDA or the EMA with respect to the promotion or marketing of medicines, vaccines and therapies.

Data Protection & Privacy

CSL collects and holds personal information about our employees and key stakeholders, such as plasma donors, healthcare professionals and patients. Unauthorised access or use of this information presents a risk to our operations.

CSL regularly assesses information security risk as we continue rapid growth globally. At the same time, we are making strategic investments in cybersecurity and cybersecurity risk management in the areas of identity and access management, network security, application and data security. We have also taken substantive efforts to protect our patients', donors' and employees' personal information through the broader use of encryption. Cybersecurity remains an important focus of CSL's senior leadership group and CSL's Audit and Risk Management Committee of the Board.

In January 2016, CSL released an updated version of our Cybersecurity and Risk Handbook to all employees. The detailed guide provides employees with a deeper understanding of the external threats and practical guidance for data, email, mobile, network and physical security to prevent cyber-breach.

We comply with relevant privacy and health regulations established in jurisdictions where we operate and are committed to safeguarding the privacy of personal information that we gather. Data Protection Officers operating across major jurisdictions oversee the governance and identification of privacyrelated matters as relevant to their operations and local laws, such as the new European General Data Protection Regulation (effective as of 25 May 2018).