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Ethics and compliance

The Novo Nordisk Foundation holds itself — and the people and organisations it works with — to clear standards of conduct, research integrity and responsible operations. The codes and policies below set out those standards and how to raise a concern.

Codes of Conduct

The Novo Nordisk Foundation maintains both an Internal Code of Conduct for its board, executive management and employees, as well as a Partner Code of Conduct for people and organisations associated with the Foundation, such as grant recipients, personnel funded by grants, organisations collaborating with us, suppliers and subsidiaries.

You can learn more about our codes of conduct here.

Confidential Reporting

The Foundation has implemented a whistleblower policy and scheme that enable people to anonymously report serious and/or recurring violations of the Foundation’s Internal Code of Conduct, Partner Code of Conduct, internal policies or applicable laws, regulations and ethical principles.

Additional information on this programme can be found here.

Conflicts of Interest

Avoiding actual or perceived conflicts of interest is paramount for the Novo Nordisk Foundation in order that we can act transparently, with integrity and in a way that maintains public trust.

For grants, our Rules for Grant Eligibility and Assessment provide guidance on when someone is ineligible to receive or evaluate a grant due to a personal, professional, or financial conflict of interest.

The Foundation has also adopted specific guidelines regarding collaboration with Novo Group companies, especially when considering grants and projects in fields where the Novo Group may have a commercial interest. These guidelines are detailed in our Executive Management-approved Guidelines for Philanthropic Collaboration with NNF-Controlled Companies.

At the employee level, Foundation employees must disclose to their manager when they have a financial or non-financial personal interest or outside loyalty that could affect their ability to perform their job without bias. Managers must ensure that such conflicts are documented and appropriately managed, such as by recusing the employee from decision-making.

Moreover, the Foundation does not tolerate nepotism, including granting preferential treatment to friends, family, or other close relations.

To support its conflict of interest programme, the Foundation maintains strict internal policies on sideline employment, outside academic activities, insider trading and giving and receiving honoraria, gifts & hospitality. In addition, the Foundation conducts regular conflict of interest disclosure exercises for senior decision-makers.

Guidance on reporting conflict of interest concerns can be found in the “Reporting Code of Conduct Concerns” section of the Partner Code of Conduct.

Standards for Good Research Practice

When funding research, the Novo Nordisk Foundation expects partners to live up to recognised standards for good research practice. These standards are detailed in our Partner Code of Conduct and available here.

Data Ethics and AI Policy

The Foundation maintains separate policies concerning:

  • data ethics
  • ethical use of AI, and
  • the specific use of AI by committee members and peer reviewers when assessing grant applications.

You can view these policies here.