Public Policy & Market Influence

Company Performance


  1. Sanofi 
  2. GlaxoSmithKline
  3. Novo Nordisk


  1. Novo Nordisk
  2. Bristol-Myers Squibb, Eli Lilly, Johnson & Johnson
  3. Sanofi


  1. AstraZeneca
  2. Abbot 
  3. Pfizer

Further Reading

2012 Public Policy (pdf)

2012 Public Policy Company Ranking

What Matters

  • Ethical and transparent lobbying practices that are monitored and enforced
  • Ethical and transparent marketing and anti-bribery/anti-corruption practices that apply internally and to third parties and are monitored and enforced
  • Engaging with external parties and memberships proactively to promote access
  • Non-pursuit of anti-competitive policies or practices

Key Trends


The leading companies, Sanofi and GlaxoSmithKline, meet higher standards for lobbying, marketing, bribery and corruption than their peers. These are reflected in their having internal codes of conduct and mechanisms to monitor and enforce them, as well as in their memberships of  international arrangements such as the UN Global Compact. This is evidence that, among the leading companies at least, we are seeing a stronger public commitment than in the past to ethical practice.

Novo Nordisk’s performance has improved markedly since 2010, moving it up 11 places to 3rd. It has access-orientated policy commitments related to competition and is the only company to commit fully to not applying data exclusivity. The company has also improved against more stringent measures relating to bribery and corruption. 

Most improved

Among the companies showing the biggest improvements since 2010, Sanofi has moved up six places because it has no pending litigation or regulatory proceedings relevant to breaches of any ethical marketing, lobbying or anti-bribery standard. Bristol-Myers Squibb, Johnson & Johnson and Eli Lilly also  rose in rank by improving transparency and implementing more explicit codes of conduct, and Bristol-Myers Squibb meets higher anti-corruption standards. These companies do, however, have further to go in creating enforcement mechanisms.

Gilead and Eisai are less developed in terms of the scale and scope of enforcement around their lobbying and marketing efforts but have better standards for bribery and corruption than in the past, including anti-corruption codes of conduct and higher enforcement standards. 


Abbott, AstraZeneca and Pfizer fell in rank through a relative lack of transparency around their lobbying and marketing practices compared with the leaders in this area. Although Abbott and AstraZeneca show some commitment to fighting bribery and corruption and have improved  their internal standards for ethical practices, there is further for them to go to meet a high standard of monitoring and enforcement mechanisms for preventing corruption.

Boehringer-Ingelheim, Daiichi Sankyo, Astellas and Takeda continue to lag, with little improvement since 2010 in  relevant lobbying, marketing and anti-corruption commitments. They also have limited transparency around their lobbying and marketing practices, and Boehringer-Ingelheim had a breach of ethical conduct codes. 

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