Partners in progress: How Novo Nordisk transformed compliance into strategy

In an era where corporate ethics and business success are often viewed as competing interests, Novo Nordisk has pioneered an approach that positions ethics and compliance as a strategic advantage.

The transition to a more progressive compliance model began around 10 years ago, according to Jill Fallows Macaluso, corporate vice president and chief compliance officer at Novo Nordisk, when the organization was operating under a corporate integrity agreement (CIA), where the compliance department primarily focused on CIA-related work.

“Business was focused on predominantly CIA-related work, but we had a vision that we needed to change the way we were working, from being this kind of reactive, corrective function, to be more proactive business partners, identifying risk on the front end,” Macaluso said at the recent Pharmaceutical Compliance Congress in McLean, Virginia.

Jill Fallows Macaluso, corporate vice president and chief compliance officer at Novo Nordisk

They initiated a pilot program with a single employee implementing a business partner model in their smallest therapy area back then, obesity. The pilot proved highly successful, according to Macaluso, and following the conclusion of the CIA, the organization expanded the initiative in 2016.

“When the CIA ended, we redeployed resources, built a whole team of business partners in 2016, had a great vision, great business plans, and we had good relationships,” she said.

The transformation succeeded through key “change champions” Macaluso explained, like panelist Gbubemi Nanna, vice president, area commercial lead at Novo Nordisk, who embraced compliance as an integral part of commercial strategy from day one, she said.

Gbubemi Nanna, vice president, area commercial lead, Novo Nordisk

“I always felt that every employee that’s a part of Novo Nordisk is on the ethics and compliance team,” Nanna told delegates.

He noted it’s “so appropriately coined business partner, because that’s really the way that we have approached it as a business partnership.” What makes this model particularly effective, Nanna said, is the early integration of compliance partners into the business process – they are embedded “sometimes even at concept or during the creative planning.”

By having compliance partners at the table from the start, the company has experienced a “tremendous amount of advantages from on a number of different fronts, in terms of speed to market and in our ability to just be more agile,” he said.

“I really do think it’s been an evolution because it’s shifted from compliance being more of an approval or a thumbs up to actually being a part of the actual creative planning process and helping to inform and help to shape not only the outcome, but the path that that leads you here,” he continued.

Competitive strategic advantage

Furthermore, ethics and compliance serve as a powerful competitive strategic gain, according to Nanna, who stated: “I view ethics and compliance as a competitive strategic advantage. I literally view it as having a culture of high ethics as providing you with a strategic advantage.”

He emphasized how maintaining high ethical standards builds trust across multiple stakeholders.

“Having a culture of ethics and compliance is critical to your corporate reputation and trust, and that’s important for a number of stakeholders, both external and internal. So that’s important for our customers, whether those are healthcare professionals, payers, regulatory agencies, etc.,” he said.

Employee engagement and satisfaction are particularly significant, with Nanna stating, “It’s important employees want to be part of a corporation that aligns with their principles and their value system. Employees are proud to be part of an ethical company.”

This foundation proves to valuable in talent acquisition, according to Nanna, where “some of our top talent ... when they do research and reconnaissance, prepared for the interview, they talk about our Novo Nordisk way ... and how ethics is a big part of the value system at the company.”

From an operational perspective, the Nanna highlighted how ethics and compliance drive efficiency. “If you’re working closely with your business partners, the speed to market is accelerating. Things don’t get held up. You don’t have to go back to the drawing board... everyone is at the table at the very beginning of the creative planning process, right from concepts all the way through fruition.”

Future collaboration between compliance and business

Macaluso’s strategy for 2025 is to “support fast, competitive commercial execution. … That’s my top priority, while living up to the highest ethical standards,” she said. In order to support Nanna and his commercial team in achieving that goal, she said they have three key priorities to do so:

1. Cultivating ethical leadership culture;

2. Reducing business friction; and

3. Enabling risk-based decision making.

“The foundation we started building in 2016 is what’s allowing us to run so fast in 2025,” Macaluso said.

Nanna gave his take on collaboration in an approach that pushes decision making authority when it comes to certain topics or compliance down to the lowest appropriate levels.

At the executive level, the company has assembled “a body of cross-functional partners, across different functions, different departments in the organization” that has been empowered to not only gather feedback but make decisions on critical topics.

The company has also established a field-level compliance structure by creating the field ambassador ethics and compliance council. This council operates at the first-line manager level, incorporating both frontline representatives and their management into the compliance framework.

“That’s a great opportunity for them to serve as conduits to provide insights directly from the field around what are some of the things that probably are getting in the way? How do we approach those? And what are some opportunities to, as Jill already said, run faster and really be more nimble?”

The initiative has successfully eliminated traditional divisions between compliance and business operations. As Nanna said, “It’s definitely not a us versus them because we’re all on the same team. We’re really all after the same things. And once we’re all reading from the same sheet of music, we all tend to arrive at the same outcome.”

Agreeing with Nanna, Macaluso said, “I think we’ve done a really beautiful job as a global organization, and it’s lined up perfectly for compliance. We really are emphasizing a leadership theme of empowerment and making empowerment work.”

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