Ethics and Compliance

At Elanco, we create trust with our customers and employees when we make decisions with integrity, so that we can protect and support the people we serve as well as our company, brand, and reputation. This starts by enabling a culture focused on Doing it Right: Elanco Everyday.

Our Ethical Foundation

Values

Elanco values inspire us to do the right things for the right reasons. The Elanco Code of Conduct sets the expectation for behavior that we demonstrate every day.

Commitment

We are committed to act legally and ethically, following the laws, regulations, policies, and procedures that govern our business.

Culture

As Elanco employees, we have a shared responsibility for developing and cultivating a culture of integrity, respect for people, and excellence. We apply good judgment, and we seek help when we’re not sure of the right thing to do.

Impact

We never underestimate the critical role each of us plays—supervisors and employees alike—in making life better for people around the world.

Elanco Code of Conduct

Our Code of Conduct is our foundation that guides our decision making and relationships, establishes our behavioral expectations, and sets the high standards against which we measure our performance.

Ethics and Compliance Program

Our global Ethics and Compliance is based on the following fundamental seven elements:

: At Elanco, all employees have a shared responsibility as owners of our company to embrace a culture of doing it right. To support employees in this effort, Elanco’s Ethics and Compliance Center of Excellence team led by our Chief Ethics and Compliance Officer has designed, implemented, and continuously monitors the program.

Elanco’s Integrated Controls Committee, comprised of cross-functional senior leaders, provides program oversight. Additionally, the Chief Ethics and Compliance Officer provides quarterly reports to senior leaders, executive officers, and the Audit Committee of the Board of Directors to support their oversight of our Ethics and Compliance Program.
: Elanco’s Code of Conduct is our foundation that guides our decision making and relationships, establishes our behavioral expectations, and sets the high standards against which we measure our performance. The Code of Conduct addresses the key principles of our 11 company policies which are further supported by global standards and procedures that address risks to Elanco’s business. Each of these are available to employees in multiple translations through Elanco’s company intranet.
: All global employees are required to complete Code of Conduct training annually. Employees may also receive targeted training from Ethics and Compliance in the areas of data privacy, anti-corruption and third-party management, and ethical interactions with external parties based on their role and responsibilities. Additionally, they have access to educational resources related to these programs on Elanco’s company intranet.
: Do It Right: Elanco Every Day is Elanco’s internal campaign under which we communicate important information to our global employees on the latest news they need to know and actions they need to take to understand and comply with the relevant external laws, regulations, and industry codes along with the internal policies, standards, and procedures that govern our business. Communications occur through townhalls, email, and our Ethics and Compliance Champion network with global communications made available on Elanco’s company intranet.
: Risk Assessments are conducted throughout our business to identify risks within our Ethics and Compliance program areas of data privacy, anti-corruption and third-party management, and ethical interactions with external parties. Risks are prioritized and action plans are implemented to mitigate these risks. This risk prioritization informs the independent and objective monitoring conducted by Ethics and Compliance that focuses on compliance with our program and associated policies, standards, and procedures.
: If monitoring identifies findings, a root cause analysis is conducted and corrective and preventative actions are developed by business partners to address the root cause. Additionally, the Chief Ethics and Compliance Officer reports monitoring findings to senior leaders, executive officers, and the Audit Committee of the Board of Directors.
: At Elanco, we foster a culture of integrity and doing the right thing in the right way. Because Elanco is committed to acting legally and ethically, we encourage employees, contractors, or suppliers to report any known or suspected violation of our Code of Conduct, policies, procedures or laws that regulate our business without fear of retaliation. Elanco’s IntegrityLine is a convenient, confidential and anonymous way for employees, contractors or suppliers to report issues, concerns or behaviors that could harm Elanco or those we serve. The IntegrityLine is available 24 hours a day, 7 days a week, and translation services are available in most languages.

When a concern is reported, Elanco has an established process to investigate those concerns. If the investigation confirms that a violation has occurred, we determine appropriate disciplinary consequences. We also conduct a root cause analysis and actions are implemented to correct and prevent violations.

Elanco does not tolerate any form of retaliation against individuals who report a concern or those who participate in an investigation.

Key Programs & Policies

Overview of our key programs and policies that underpin our Ethics and Compliance program at Elanco:

Enterprise Risk Management

Anti-Corruption & Third-Party Management

Ethical Interactions with External Parties

Data Privacy

Enterprise Risk Management

Enterprise Risk Management (ERM) is designed to identify enterprise-wide risks that pose a threat to Elanco operations, our strategy, and our business objectives. The ERM program is facilitated by the Chief Ethics and Compliance Officer with internal program oversight provided by the Elanco ERM Core Team comprised of cross-functional executive officers and senior leaders. Enterprise risks are assessed and prioritized based on their impact to our strategy and objectives as well as their likelihood of occurrence. Mitigating action plans are developed by risk owners and sponsors for each enterprise risk. Reviews occur quarterly and annually to identify changes to current risks as well as new or emerging risks. The Elanco Executive Committee and Board of Directors provide oversight of enterprise risks, and they receive quarterly updates regarding progress on our mitigating action plans and annual updates regarding Elanco’s enterprise risk profile.