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To help ensure that all employees uphold high legal and ethical standards, we embed our expectations in our Code of Conduct.
A foundational document across our company, our Code of Conduct is based on our ICARE shared values.
It describes the fundamental principles and policies that shape our work, covering a wide range of topics that may occur when interacting with customers, industry partners, regulators and each other.
It gives helpful guidance regarding where to turn with questions or concerns about the right thing to do.
As noted in our Code of Conduct, we seek business partners who share our values and commitment to doing business with integrity.
In addition to our Code of Conduct, McKesson has established compliance policies and procedures that are designed to prevent and detect potential violations of applicable laws, regulations, and ethical standards.
These policies are accessible to employees on our intranet and other means.
Compliance risk assessment We regularly assess compliance and regulatory risks across our operations.
Our approach includes conducting regular risk assessments and developing comprehensive work plans to mitigate compliance risks, with many actions owned by the business.
Compliance leaders also participate in the company’s annual enterprise risk assessment which focuses on risks that could impact the organization in achieving its strategic and operational objectives.
Privacy program Patient, customer and employee privacy, security and confidentiality are critical at McKesson, and we are committed to maintaining the privacy and security of personal information.
McKesson has adopted specific policies, procedures and privacy principles that guide how we collect, store, access and use personal information throughout the company.
We provide clear and timely notice about our privacy practices.
This includes how we collect, use, retain, protect and disclose personal information.
Our Privacy Notice is available on our website.
McKesson has established a Global Privacy Office responsible for the support and coordination of key privacy initiatives across the enterprise involving the collection, use and disclosure of personal information, including cross-border data transfers.
This includes developing the enterprise privacy program strategy, developing and maintaining enterprise policies and training, along with developing enterprise tools, processes and controls for the promotion of organizational consistency and efficiency.
Anti-corruption program We succeed based on the quality of our products, services, and people.
Corruption or bribery of any sort is counter to the way we do business and is strictly prohibited.
Our policies prohibit promising, offering, or giving “anything of value” with the intent to improperly influence the conduct of a government official, an employee or representative of our commercial business partners, a medical professional, and others.
Our policies also do not allow the receipt of anything of value that could be perceived to improperly influence our conduct.
We expect our business partners and third parties acting on our behalf to comply with all applicable anti-bribery and anti-corruption laws and standards.
This includes third parties who might interact with a customer or government official on our behalf.
Training and communication McKesson has implemented a focused compliance training and communications plan to educate employees, business partners and our Board on business risks and policies relevant to their roles.
For example, McKesson delivers training on its Code of Conduct to the Board on an annual basis.
Our approach combines various training methods reinforced through supporting communication resources available via our corporate intranet and through leadership messaging and communications.
These training and communication resources are McKesson has adopted specific policies, procedures and privacy principles that guide how we collect, store, access and use personal information throughout the company.
Compliance officer assessed periodically and updated to align with changes in laws, regulations and/or policies.
Monitoring and testing We have implemented a range of compliance monitoring and testing activities, including data analytics, to monitor the adequacy and effectiveness of our compliance programs to mitigate risks.
These programs enable us to identify trends and potential red flags, provide insights about our program’s robustness, and identify opportunities for continuous improvement.
Identified issues and opportunities are addressed through action plans.
Confidential reporting channels and internal investigations McKesson employees are a critical line of defense in ensuring that we detect and respond to potential compliance issues.
McKesson offers multiple channels for employees and third parties to raise concerns.
Employees may contact any people leader, compliance officer, human resources, or the legal department with concerns.
In addition, McKesson provides confidential integrity hotlines available 365 days a year with multiple language capabilities.
McKesson’s integrity hotlines allow employees and third parties to raise concerns (anonymously if they wish) about potential violations of law, regulation, McKesson’s Code of Conduct, McKesson policies, or any other actual or potential misconduct.
An independent third-party provider (in Europe, an ombudsman) answers and documents all calls before forwarding them to McKesson.
The integrity hotlines are publicized in multiple ways, including in our Code of Conduct, in training materials, on our internal websites, and through awareness campaigns.
Our internal policies are designed to protect employees from retaliation for raising concerns, asking questions, seeking guidance or participating in an investigation.
By fostering an open reporting environment where all employees have confidence that they can speak up without fear of retaliation, we seek to advance our culture of compliance and integrity.
McKesson takes all concerns seriously and investigates allegations of misconduct.
After investigating, we develop and carry out a corrective and preventive action plan, as appropriate.
Consistent with our corporate governance guidelines, we also provide reports of significant matters to the Compliance Committee and the Audit Committee of the Board.
The Audit Committee of the Board also receives reports on allegations and investigations regarding accounting, internal accounting controls, or audit matters.
We endeavor to provide safe, high-quality products to our customers and their patients; a commitment that is guided by our company’s purpose and mission.
Additionally, the suppliers of our internationally sourced private-label products must agree to the McKesson Supplier Sustainability Principles (MSSP), which cover compliance with applicable laws along with adherence to strict policies on protecting workers, preparing for emergencies, and protecting the environment.
Global sourcing and supply chain management Our company-wide values are the foundation of McKesson’s approach to being a responsible corporation.
Our Global Sourcing organization is responsible for identifying potential overseas suppliers for our private-label brands.
Once suppliers are identified, we begin assessment and qualification processes to determine if these suppliers meet our criteria.
Global Sourcing To support our Global Sourcing program, we have employees in certain countries where our private-label products are manufactured by third party suppliers.
These McKesson employees focus on product quality, supply chain and logistics, and sourcing; and perform product inspections and audits during factory visits.
Suppliers must complete assessments and audits covering CGMP and our own responsible sourcing criteria, outlined in the MSSP in accordance with our protocols.
Our Global Sourcing team may only procure items from suppliers after the supplier fulfills our standards and are added to our approved supplier list.
Furthermore, new internationally sourced private-label products undergo product qualification processes, which can involve using benchmark products, developing inspection criteria and private- label artwork to help ensure compliance with brand guidelines and regulatory obligations.
We have in-house licensed customs brokers for shipments bound for the U.S. that enable the importation of products into the U.S. Our companywide values are the foundation of McKesson’s approach to being a responsible corporation.
Operations >Table of Contents | Just as we hold ourselves accountable, we also hold our suppliers accountable for the quality of their products and services.
We audit suppliers through our Global Sourcing program periodically — pursuant to a documented audit plan — to help ensure they remain in compliance with our expectations.
Suppliers are prohibited from making any changes to a product without our written approval.
Responsible Sourcing A reflection of McKesson’s expectations of our supplier partners, the MSSP guide us in how and where we source our private-label products.
Established in program provides a framework that holds our international private-label suppliers to an auditable set of expectations.
Private-label suppliers outside the U.S. must agree to comply with the MSSP, which address compliance with applicable laws along with adherence to our principles on protecting workers, preparing for emergencies and protecting the environment.
In accordance with our responsible sourcing processes, we conduct onsite audits — or consult other appropriate resources — to periodically monitor compliance with the MSSP, including document review, a factory tour, and interviews with workers.
We document findings and require suppliers to remediate instances of noncompliance.
We focus our remediation efforts on issues around labor and working conditions, health and safety, environmental, legal compliance, permits, business integrity, risk management and emergency response.
For example, we work with suppliers to address concerns regarding living conditions of workers in factory dormitories, and we provide training for suppliers as appropriate and applicable.
When issues are identified, McKesson auditors work with the supplier to ensure improvements are made.
Audit findings or non-conformances are prioritized based on risk.
When critical issues are identified, McKesson requires a timely response from the supplier.
If a supplier fails to adequately remediate the issue, the relationship is reevaluated and, if necessary, terminated.
We strive to conduct business with companies that share our values, ethics, and sustainability principles and that effectively incorporate these values into their business practices and management systems.
To that end, McKesson seeks to continuously improve its Responsible Sourcing program to ensure that it addresses the needs and risks of today.
Product quality and safety As a company in the healthcare industry, we are subject to a wide range of complex and evolving regulatory requirements.
We are committed to We audit suppliers through our Global Sourcing program periodically — pursuant to a documented audit plan — to help ensure they remain in compliance with our expectations.
Operations >Table of Contents | regulatory excellence and compliance with laws and regulations that apply to us in all aspects of our operations, as well as continuous improvement of our processes to help ensure we meet the needs of all stakeholders.
Good Manufacturing and Distribution Practices guidelines in Europe.
Our quality management systems are based on international procedures and industry standards to help ensure the products we handle and distribute, the products we source in our private-label line of business, and the packaging and labeling thereof, follow applicable regulations and are in line with or exceed industry best practices.
For example, more than our All About Health Pharmaceuticals business, are ISO 9001 certified, and our Europe-based McKesson Global Sourcing Quality and Regulatory team is certified to the ISO 13485 standard.
When receiving our globally sourced private-branded products, we verify the quantity, supplier name and product name through the purchase order, and we monitor that the product is not set to expire soon.
When potential product quality incidents occur, we work to respond promptly and follow a Corrective Action – Preventive Action (CAPA) process.
To prevent counterfeit products from entering the legal distribution network and to help ensure the integrity of the products we take ownership of, we follow a supplier qualification procedure for vendors.
Potential suppliers are vetted using industry accepted tools.
A mutually agreed upon distribution agreement and accompanying policy and procedures document govern the relationship.
As part of this process, we perform regular audits and checks of authorizations and certifications, as appropriate.
We comply with manufacturer requirements for handling and distributing products.
The needs and requirements of various manufacturers are different, so our contractual commitments, controls and processes vary by manufacturer.
We evaluate and validate manufacturers’ performance against their contractual arrangements.
Each year, we also hold a supplier award ceremony to recognize suppliers for their commitment to collaboration, and supply chain safety, quality and efficiency.
McKesson transports essential medical and surgical products across the globe, and it is critical that we track shipments at each stage of their journey through our warehouses.
If we identify suspect product in our possession, it is quarantined and reported to a quality review team.
McKesson works with manufacturers and customers to communicate recalls and suspect product.
In the U.S., McKesson complies with the Drug Supply Chain Security Act (DSCSA) which, since requires that sellers and purchasers of prescription drug products exchange lot-level transaction data.
When McKesson acquires prescription drug products, we work to ensure that we receive adequate transaction information, transaction history and a transaction statement from the seller, which is aligned to the physical goods received.
McKesson is focused on the next stage of the DSCSA which occurs on November are serialized in the U.S. and required to be traceable through the supply chain from manufacturer to dispenser.
McKesson is developing the technology to scan individual saleable units capturing National Drug Code (NDC), serial, lot, and expiry — and validating those data points against the electronic DSCSA data provided by the supplier.
McKesson will then assign those serialized drug products to a customer providing them with an electronic DSCSA transaction data set that aligns with the physical goods sold.
In Europe, we follow the Falsified Medicines Directive, which requires batch tracking of certain medicinal products.
When products enter our warehouses, we record the product code, expiration date and batch number.
We track the product at every stage of its journey in the warehouse — from replenishment, to picking, to returns.
Employees can either scan the information or enter it manually.
If an inaccuracy occurs, the tracking system generates an alert.