Innovation With Integrity

At Incyte, we are striving to make a difference in healthcare, to improve the lives of patients, and to build sustainable value for our stockholders. Achieving these goals depends largely on our commitment to conducting business ethically.

The continued success of Incyte is dependent on the confidence we earn from our customers, patients, fellow employees, regulators and stakeholders. We gain the right to operate as a biopharmaceutical company by adhering to our commitments, displaying honesty and integrity, and reaching our Company goals through ethical conduct. To that end, the way we conduct our business is as important as the results we achieve.

— Hervé Hoppenot, CEO Incyte

The Code of Business Conduct and Ethics (the "Code") serves as our roadmap for acting ethically whenever and wherever we conduct business. Together with other company policies which provide more detailed information on specific topics, the Code will help us apply basic principles to our daily conduct so that we can ensure we are following both the letter and the spirit of the law and conducting business with honesty and integrity. We expect everyone with whom we conduct business to honor the principles outlined in the Code.

Click here to access the Code of Business Conduct and Ethics >

  • Leadership and Structure
  • Written Standards
  • Education and Training
  • Internal Lines of Communication
  • Auditing and Monitoring
  • Responding to Potential Violations
  • Corrective Action Procedures

Our Comprehensive Compliance Program is one of the key components of our commitment to the highest standards of corporate conduct and has been tailored to fit the unique environment of our company. Our Compliance Program is also dynamic, and we regularly review and enhance our Compliance Program to meet our evolving compliance needs.

LEADERSHIP AND STRUCTURE

  • Compliance Officer. We have designated a senior-level official in our organization to serve as our corporate compliance officer. We are committed to our Compliance Officer having the ability to effectuate change within the organization as necessary and to exercise independent judgment. Our Compliance Officer is charged with the responsibility for developing, operating, and monitoring the Comprehensive Compliance Program.
  • Compliance Committee. Incyte has established a Compliance Committee to advise the Compliance Officer and assist in the implementation of the Compliance Program.

WRITTEN STANDARDS

Incyte’s Code of Business Conduct and Ethics (the "Code") is our statement of ethical and compliance principles that guide our daily operations. The Code establishes that we expect management, employees, and agents of the company to act in accordance with law and applicable company policy. The Code articulates our fundamental principles, values, and framework for action within our organization.

EDUCATION AND TRAINING

A critical element of our Compliance Program is the education and training of our employees on their legal and ethical obligations under applicable federal healthcare program requirements. Incyte is committed to taking all necessary steps to effectively communicate our standards and procedures to all affected personnel. Moreover, Incyte will regularly review and update its training programs, as well as identify additional areas of training on an "as needed" basis.

INTERNAL LINES OF COMMUNICATION

Incyte is committed to fostering dialogue between management and employees. Our goal is that all employees, when seeking answers to questions or reporting potential instances of fraud and abuse, should know whom to turn to for a meaningful response and should be able to do so without fear of retribution. To that end, we have adopted open-door policies, as well as confidentiality and non-retaliation policies.

In addition, Incyte also has a Helpline that provides a means for employees or external parties to report a compliance concern or misconduct. This Helpline is managed by a third-party vendor and provides the option to report anonymously as permitted by local law.

AUDITING AND MONITORING

Incyte’s Compliance Program includes efforts to monitor, audit, and evaluate compliance with the company’s compliance policies and procedures. The nature of our reviews as well as the extent and frequency of our compliance monitoring and auditing varies according to a variety of factors, including new regulatory requirements, changes in business practices, and other considerations.

RESPONDING TO POTENTIAL VIOLATIONS

Incyte’s Compliance Program includes clear disciplinary policies that set out the consequences of violating the law or company policy. Although each situation is considered on a case-by-case basis, we will consistently undertake appropriate disciplinary action to address inappropriate conduct and deter future violations.

CORRECTIVE ACTION PROCEDURES

Our Compliance Program requires the company to respond promptly to potential violations of law or company policy, take appropriate disciplinary action, assess whether the violation is in part due to gaps in our policies, practices, or internal controls, and take action to prevent future violations.

Incyte recognizes the importance of working with suppliers, distributors, vendors, and other business partners (collectively, "Third Parties") who share our values and operate in a responsible and ethical manner. It is our goal to always operate in compliance with all applicable rules and regulations. As such, we expect that all Third Parties with whom we do business operate in compliance with all applicable laws and regulations of the countries, states, and localities in which they operate. This includes, but is not limited to, business conduct, product quality, labor and employment practices, health and safety, and environmental protection. As a responsible corporate citizen, Incyte expects its Third Parties to conform their practices to any published standards for their industry, obtain all applicable permits, and operate in accordance with permit limitations and requirements at all times. The standards and expectations we have for our Third Parties mirror those which we set for ourselves as reflected in our Code of Business Conduct and Ethics and we expect our Third Parties to be familiar with and conform themselves to such standards.

  • US Sunshine Act
  • Declaration of Compliance for California
  • Vermont Disclosure Act
  • Compassionate Use

lncyte recognizes that ethical relationships with healthcare professionals and organizations are critical to its mission of helping patients by developing and marketing new medicines. We are committed to ensuring that our interactions with healthcare professionals and organizations are professional exchanges intended to enhance the practice of medicine for the benefit of patients, and to following the highest standards of integrity, ethical conduct, and full compliance with the laws, regulations, and applicable codes of marketing practice, including the US PhRMA Code on Interactions with Healthcare Professionals (the "PhRMA Code"). Additionally, we also comply with applicable disclosure and declaration requirements related to interactions and transfers of value provided to reportable recipients, such as the US Sunshine Act.

US Sunshine Act

The Physician Payment Sunshine Act (Sunshine Act) was passed as part of healthcare reform in March 2010 and was in effect as of August 1, 2013. The Sunshine Act, also referred to as "Open Payments," requires pharmaceutical manufacturers such as Incyte, medical device companies, and group purchasing organizations (GPOs) to track and report certain ownership interests, payments, and transfers of value, including meals, refreshments, educational items, and fee-for-service compensation provided to US physicians and teaching hospitals.

Incyte complies with the disclosure requirements and encourages you to reference the Open Payments website, which is managed by the Centers for Medicaid and Medicare Services (CMS), for additional information.

If you have any questions or inquiries related to data submitted by Incyte, please contact our Transparency team at transparency@incyte.com

Declaration of Compliance for California

Click the documents below for a description of Incyte’s Comprehensive Compliance Program pursuant to the California Marketing Practices Act:

Declaration of Compliance for CA

Compliance Program for CA

Additional Disclosures:

Vermont Disclosure Act

Vermont law 33 V.S.A. §2005a mandates that pharmaceutical manufacturers disclose to Vermont physicians and other prescribers the average wholesale price (AWP) of drugs they market within the state as well as the prices of other drugs in the same therapeutic class. Under Vermont law, "therapeutic class" is defined as the therapeutic class listed in the 2004 American Hospital Formulary Service Pharmacologic-Therapeutic Classification published by the American Society of Health System Pharmacists (available at http://www.ashp.org).

Incyte Corporation has listed these therapeutic class prices in Long Form Disclosures as required under Vermont Law.

Access the Long Form Disclosure for:

>> JAKAFI® (ruxolitinib)

Access the Short Form Disclosure for:

>> JAKAFI® (ruxolitinib)

Compassionate Use

Click here to read our Policy on Compassionate Use.

Incyte honors its trusted relationships with healthcare professionals, patients, caregivers, consumers, employees, and business partners by being transparent about how we collect, use, and share data. We encourage you to learn more about our Privacy practices, including our company policy, Privacy Notices, and contact information for our Privacy Office.

Click here to be directed to our Privacy page >

Incyte is committed to keeping the lines of communication open and fostering a speak-up culture.  The Compliance Helpline provides multiple options to speak up confidentially through a third party and report concerns or misconduct:

United States: 1-855-462-3411
Switzerland: 0-800-890011, then 855-845-3448
Web: incyte.ethicspoint.com