2010 GRI Index

This report was prepared in accordance with the Global Reporting Initiative (GRI) G3 Guidelines, a voluntary framework to guide organizations reporting on their economic, environmental and social performance.

The GRI Guidelines are the most commonly used global reporting framework and help facilitate rigor, transparency and accountability in Corporate Citizenship reporting by organizations regardless of size, sector or location.

Under the GRI G3 Guidelines, organizations must self-declare the level to which they have applied the GRI Guidelines, designated by an Application Level of A, B or C, where A represents the most comprehensive level of reporting. In our second report, Biogen Idec has achieved an Application Level of B. For additional information, please refer to www.globalreporting.org.

Global Reporting Initiative Indicators

1. Strategy and Analysis

1.1

Statement from the senior decision maker of the organization (e.g. CEO, chair or equivalent senior position) about the relevance of sustainability to the organization and its strategy.

View our CEO Message.

1.2

Description of key impacts, risks and opportunities.

View our priority issues. Compared to our last report, we have added the issue of Biosimilars. We have also elevated the importance of Climate Change/Greenhouse Gas Emissions.

 

2. Organizational Profile

2.1

Name of the organization.

Biogen Idec

2.2

Primary brands, products and/or services.

View our product pipeline.

2.3

Operational structure of the organization, including main divisions, operating companies, subsidiaries and joint ventures.

View our organizational structure and partnerships.

2.4

Location of the organization’s headquarters.

Our company is headquartered in Weston, MA.

2.5

Number of countries where the organization operates, and names of countries with either major operations or that are specifically relevant to the sustainability issues covered in the report.

View our organizational structure.

2.6

Nature of ownership and legal form.

Biogen Idec is listed on the NASDAQ stock exchange under the symbol BIIB.

2.7

Markets served (including geographic breakdown, sectors served and types of customers/beneficiaries).

Read our corporate overview and see where we operate.

2.8

Scale of the reporting organization, including: number of employees, net sales, total capitalization broken down in terms of debt and equity, quantity of products or services provided.

This information is provided through our Key Performance Indicators.

2.9

Significant changes during the reporting period regarding size, structure or ownership.

In late 2010, we adopted a new Framework for Growth that has narrowed our research focus and resulted in some structural changes. We also moved our corporate offices to our new headquarters in Weston, MA in mid-2010.

2.10

Awards received in the reporting period.

Biogen Idec is included in the Dow Jones Sustainability Index.

 

3. Report Parameters

 

3.1

Reporting period (e.g., fiscal/calendar year) for information provided.

View the reporting period.

3.2

Date of most recent report (if any).

2009

3.3

Reporting cycle (annual, biannual etc.).

Annual

3.4

Contact point for questions regarding the report or its contents.

Please provide comments to corporatecitizenshipreport@biogenidec.com.

3.5

Process for defining report content, including: materiality, prioritizing topics within the report and identifying stakeholders the organization expects to use the report.

View our process for defining our Priority Issues.

3.6

Boundary of the report (e.g., countries, subsidiaries, leased facilities, joint ventures, suppliers).

View our report boundaries.

3.7

State any specific limitations on the scope or boundary of the report.

The report includes impacts associated with our owned and operated facilities. It does not include impacts of our vendors or partners. Our environmental data includes only our main locations (Weston, MA; Cambridge, MA; San Diego, CA; and Research Triangle Park in the United States and Hillerød, Denmark). For energy and greenhouse gas data, we also included business travel (air and fleet).

3.8

Basis for reporting on joint ventures, subsidiaries, leased facilities, outsourced operations and other entities that can significantly affect comparability from period to period and/or between organizations.

In 2010, Biogen Idec announced structural changes.

3.9

Data measurement techniques and the bases of calculations, including assumptions and techniques underlying estimations applied to the compilation of the Indicators and other information in the report.

Biogen Idec used numerous data measurement techniques in responding to the GRI Indicator Protocols.

3.10

Explanation of the effect of any restatements of information provided in earlier reports, and the reasons for such restatement (e.g., mergers/acquisitions, change of base years/periods, nature of business, measurement methods).

In our 2010 report, we added business travel to the energy intensity component of our Risk Weighted Index. Business travel impacts were not included in the 2009 report. While this addition increases our total environmental footprint, we believe it will allow us to better measure, manage and reduce the impacts of that travel.

In our 2009 report, total giving figures excluded grants for fellowships and included Foundation administrative expenses. We also double counted donations for disaster relief. In our 2010 report, to provide a clearer picture of total financial impact, giving figures include grants for fellowships and exclude Foundation administrative expenses, which is a small percentage of the overall budget.

3.11

Significant changes from previous reporting periods in the scope, boundary, or measurement methods applied in the report.

In 2010, we moved our corporate headquarters to Weston, MA. Our environmental data now includes data from our new campus, as well as business travel (air and fleet).

3.12

Table identifying the location of the Standard Disclosures in the report.

This is the table of Standard Disclosures. Click here to go to the top of the page.

3.13

Policy and current practice with regard to seeking external assurance for the report. If not included in the assurance report accompanying the sustainability report, explain the scope and basis of any external assurance provided. Also explain the relationship between the reporting organization and the assurance provider(s).

Trucost externally validated 2010 data for water use, energy use, greenhouse gas emissions for fleet and travel, and solid waste.

 

4. Governance, Commitments and Engagement

4.1

Governance structure of the organization including committees under the highest governing body responsible for specific tasks, such as setting strategy or organizational oversight.

View our governance structure and approach.

4.2

Indicate whether the chair of the highest governance body is also an executive officer (and, if so, his/her function within the organization’s management and the reasons for this arrangement.)

The Chairman of the Board is not an executive officer and is independent.

4.3

For organizations that have a unitary board structure, state the number of members of the highest governance body that are independent and/or non-executive members.

All of our directors and nominees for director, other than Mr. Scangos, our Chief Executive Officer, satisfy the independence requirements of The NASDAQ Stock Market, Inc. (NASDAQ).

4.4

Mechanisms for shareholders and employees to provide recommendations or direction to the highest governance body.

View mechanisms for providing information to our Board of Directors.

4.5

Linkage between compensation for members of the highest governance body, senior managers, and executives (including departure arrangements), and the organization's performance (including social and environmental performance).

View our governance structure and approach.

4.6

Processes in place for the highest governance body to ensure conflicts of interest are avoided

View processes to avoid conflicts of interest on page 23 in Code of Conduct.

4.7

Processes for determining qualifications and expertise of the members of the highest governance body for guiding the organization's strategy on economic, environmental, and social performance and the status of their implementation.

The Corporate Governance Committee is responsible for leading the search for qualified board members as detailed in our Corporate Governance Committee Charter.

4.8

Internally developed statements of mission and values, codes of conduct, and principles relevant to economic, environmental and social topics.

Our Code of Conduct and Sustainability Policy outline such values and principles. View our Code of Conduct.

4.9

Procedures of the highest governance body for overseeing the organization’s identifications and management of economic, environmental and social performance, including relevant risks and opportunities and adherence or compliance with internationally agreed standards, codes of conduct and principles.

View our management approach and governance structure.

4.10

Processes for evaluating the highest governance body’s own performance, particularly with respect to economic, environmental and social performance.

Our process for evaluating director qualification standards are described in our 2010 Notice and Proxy beginning on page 17.

4.11

Explanation of whether and how the precautionary approach or principle is addressed by the organization.

Biogen Idec applies the precautionary approach in ensuring the safety of patients. This includes terminating products in development if the safety profile is found to be too risky.

4.12

Externally developed economic, environmental and social charters, principles or other initiatives to which the organization subscribes or endorses.

The external charters, principles and other initiatives to which Biogen Idec subscribes are delineated in our Code of Conduct.

4.13

Memberships in associations (such as industry associations) and/or national/international advocacy organizations.

View an illustrative list of our memberships.

4.14

List the stakeholder groups engaged by the organization.

View our stakeholders and process for identifying and engaging with them.

4.15

Basis for identification and selection of stakeholders with whom to engage.

View our stakeholders and process for identifying and engaging with them.

4.16

Approaches to stakeholder engagement, including frequency of engagement by type and by stakeholder group.

View our stakeholders and process for identifying and engaging with them.

4.17

Key topics and concerns that have been raised through stakeholder engagement, and how the organization has responded to those key topics and concerns, including through its reporting.

View our process for defining our priority issues.

 

Economic Performance Indicators

 

Management Approach

We employ robust Corporate Governance practices to manage our economic performance and growth strategy. We detail our performance and highlight our future growth strategy in our 2010 Annual Review, including the launch of our Framework for Growth initiative in late 2010. Additional information can be found in our 2010 Proxy Statement and Review.

EC1

Direct economic value generated and distributed, including revenues, operating costs, employee compensation, donations and other community investments, retained earnings, and payments to capital providers and governments.

Certain components of this indicator are included in our list of Key Performance Indicators.

EC2

Financial implications and other risks and opportunities for the organization’s activities due to climate change.

We have identified a number of potential risks associated with climate change, including:

  • Physical risk to property and employees, including increased droughts, hurricane severity, power or communications failures and flooding, which could affect our operations.
  • Operating and financial risks, including extreme weather events and rising seas, that could disrupt transportation of goods/services/employees and physically impact our R&D and manufacturing sites. We could also be impacted financially if sectors we source from become subject to greenhouse gas regulations.
EC3

Coverage of the organization's defined benefit plan obligations.

In the United States, we do not have any defined benefit plan obligations. Outside of the United States, we make government-mandated pension contributions.

EC8

Development and impact of infrastructure investments and services provided primarily for public benefit through commercial, in-kind or pro bono engagement.

Read about our ActiveAccessTM program and philanthropic commitments.

 

Environmental Performance Indicators

 

Management Approach

Biogen Idec is committed to operating our business sustainably. The Biogen Idec Corporate Sustainability Council, headed by our CEO, is responsible for setting the sustainability vision and strategy for our organization, which includes our environmental strategy. Additionally, we maintain an Environmental, Health and Safety organization, governed by our Environmental, Health and Safety Policy. We provide regular trainings to members of this group based upon their functional responsibilities. Performance is monitored and managed using our Environmental Management System. The system allows us to track trends, identify issues and create and ensure implementation of corrective and preventative action plans to improve performance.

All suppliers are subject to our Code of Conduct, which cites the specific policies above. Additionally, we are working to improve the environmental performance of our supply chain through the Pharmaceutical Supply Chain Initiative.

Beyond this, Biogen Idec has established a risk-weighted environmental index for our environmental footprint. We set a goal of reducing our overall footprint by 15 percent by 2015, compared to our 2006 baseline.

EN3

Direct energy consumption by primary energy source.

Total energy intensity, which includes direct and indirect, is featured in our list of Key Performance Indicators.

EN4

Indirect energy consumption by primary source.

Total energy intensity, which includes direct and indirect, is featured in our list of Key Performance Indicators.

EN5

Energy saved due to conservation and efficiency improvements.

We do not have total figures for energy conservation efforts, but do provide examples of some initiatives that have led to energy savings. We also provide a list of energy-related projects to the Carbon Disclosure Project (CDP).

EN6

Initiatives to provide energy-efficient or renewable energy based on products and services, and reductions in energy requirements as a result of these initiatives.

We do not have total figures for all energy conservation efforts, but do provide examples of some initiatives that have led to energy savings. We also purchase Renewable Energy Credits (RECs) to offset the impact of our Weston headquarters. In 2010, we purchased 2,522,185 kilowatt hours (kWh).

EN8

Total water withdrawal by source.

View this information in our list of Key Performance Indicators.

EN9

Water sources significantly affected by withdrawal of water.

All of our water is drawn from municipal sources. We do not believe we significantly affect any water sources, but continue to work to reduce our water consumption. We also provide a list of water-related projects to the CDP.

EN10

Percentage and total volume of water recycled and reused.

View this information in our list of Key Performance Indicators.

EN11

Location and size of land owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas.

This indicator is not material to our business. View our priority issues

EN12

Description of significant impacts of activities, products and services on biodiversity in protected areas and areas of high biodiversity value outside protected areas.

This indicator is not material to our business. View our priority issues.

EN13

Habitats protected or restored.

This indicator is not material to our business. View our priority issues.

EN14

Strategies, current actions and future plans for managing impacts on biodiversity.

This indicator is not material to our business. View our priority issues.

EN15

Number of IUCN Red List species and national conservation list species with habitats in areas affected by operations, by level of extinction risk.

This indicator is not material to our business. View our priority issues.

EN16

Total direct and indirect greenhouse gas emissions by weight.

View this information in our list of Key Performance Indicators.

EN17

Other relevant indirect greenhouse gas emissions by weight.

View this information in our list of Key Performance Indicators.

EN18

Initiatives to reduce greenhouse gas emissions and reductions achieved.

We do not have total figures for energy conservation efforts, but provide examples of some initiatives that have led to energy savings. We also provide a list of energy-related projects to the CDP. Additionally, we purchase RECs to offset the impact of our Weston campus. In 2010, we purchased 2,522,185 kWh.

EN20

NOx, SOx and other significant air emissions by type and weight.

We track the release of NOx, SOx and CO from Cambridge power plant. Data in metric tons from 2008-2010 is as follows:

Year

NOx SOx CO
2008 2 0 1
2009 5 0 3
2010 6 0 5

 

EN22

Total weight of waste by type and disposal method.

View our "Waste to Landfill" data in our list of Key Performance Indicators. All other waste is incinerated at waste-to-energy facilities, composted or recycled. Data in metric tons from 2008-2010 is as follows:

Year

Compost
Recycled
Waste-to-energy
2008
30 1,163 516
2009 123 1,504 465
2010 136 1,361 437

 

EN23

Total number and volume of significant spills.

Biogen Idec did not report any spills in 2008.  In 2009, we reported two spills. In Cambridge, food-grade propylene glycol spilled into our Cambridge sewer system due to a mechanical failure. The seal was replaced, and the sewer system was cleaned. In Hillerød, Denmark, citric acid was wrongly disposed of in a public drain. After the incident, systems and training were upgraded to prevent future incidents. In 2010, in Hillerød, Denmark, an oil spill was discovered in the soil after asphalt was removed in a parking lot. The soil was removed, and no deeper contamination was found.

EN24

Weight of transported, imported, exported or treated waste deemed hazardous under the terms of the Basel Convention Annex I, II, III, and VIII, and percentage of transported waste shipped internationally.

We produce both chemical and medical waste, all of which is incinerated for waste-to-energy purposes. Total metric tons of waste include 165 in 2008, 342 in 2009 and 205 in 2010. We do not ship any waste internationally.

EN25

Identity, size, protected status and biodiversity value of water bodies and related habitats significantly affected by the reporting organization’s discharges of water and runoff.

This indicator is not material to our business. View our priority issues.

EN26

Initiatives to mitigate environmental impacts of products and services, and extent of impact mitigation.

View this information in our Environment Section.

EN28

Monetary value of significant fines and total number of nonmonetary sanctions for noncompliance with environmental laws and regulations.

Between 2008 and 2010, Biogen Idec paid one fine of $668. In Research Triangle Park, a glycol return line drain valve in our manufacturing facility was left open, resulting in glycol spilling into a public drain. We notified the town, which was able to process the contaminants and put in place corrective actions to mitigate risk of future incidents.

 

Labor Practices and Decent Work Performance Indicators

 

Management Approach

Biogen Idec follows laws, regulations and international conventions related to labor practices and ensuring decent work, including the ILO Tripartite Declaration of Principles Concerning Multinational Enterprises and Social Policy and the Organisation for Economic Co-operation and Development Guidelines for Multinational Enterprises. Specific commitments to Respect in the Workplace and Workplace Health and Safety are outlined in our Code of Business Conduct. Employees are responsible for upholding the Code. Suppliers are also subject to the Code.

If employees identify illegal activity or activity in violation of the Code of Conduct, they should report those violations to their management or a representative in the Human Resources, Legal or Compliance organizations, or through the Compliance Hotline. Incidents are investigated and corrective actions are taken as necessary according to company policy.

Our Executive Vice President of Human Resources is responsible for all aspects of human resources management and oversees our Human Resources department, charged with executing a number of programs related to employment, training and education, and diversity and equal opportunity. Employee Heath and Safety is overseen by our Environment, Health and Safety department.

LA1

Total workforce by employment type, employment contract, and region, broken down by gender.

Certain components of this indicator are included in our list of Key Performance Indicators.

LA2

Total number and rate of new employee hires and employee turnover by age group, gender and region.

Overall employee turnover is included in our list of Key Performance Indicators.

LA3

Benefits provided to full-time employees that are not provided to temporary or part-time employees, by major operations.

Biogen Idec offers a highly competitive benefits and rewards package in each country where we operate; however, not every type of temporary or part-time employment category receives all of these benefits. 

LA4

Percentage of employees covered by collective bargaining agreements.

Approximately 100 of our 4,864 employees, or 2 percent, of our staff is under a collective bargaining agreement. All of these employees work in our Hillerød, Denmark, manufacturing facility.

LA5

Minimum notice period(s) regarding operational changes, including whether it is specified in collective agreements.

At our Hillerød, Denmark, facility, the minimum notice period is based on seniority and specified in the collective bargaining agreement. Notice periods may vary anywhere from three and six months.

LA6

Percentage of total workforce represented in formal joint management-worker health and safety committees that help monitor and advise on occupational health and safety programs.

At our Hillerød, Denmark, facility, we have an Environment, Health and Safety organization that is composed of approximately 10 percent of our workforce at that location.

LA7 Rates of injury, occupational diseases, lost days, and absenteeism, and number of work-related fatalities by region.

Overall employee turnover is included in our list of Key Performance Indicators.

LA10 Average hours of training per year per employee by employee category.

Average learning hours per employee is included in our list of Key Performance Indicators.

LA12

Percentage of employees receiving regular performance and career development reviews.

All Biogen Idec employees receive a performance and career development review, annually.

LA13

Composition of governance bodies and breakdown of employees per category according to gender, age group, minority group membership and other indicators of diversity.

The Board is composed of three women and nine men.

 

Human Rights Performance Indicators

 

Management Approach

Biogen Idec currently has manufacturing operations in the United States and Denmark. All other locations house corporate offices and laboratory facilities.

In every country where we operate, Biogen Idec follows all laws, regulations and international conventions related to human rights, including the ILO Tripartite Declaration of Principles Concerning Multinational Enterprises and Social Policy and the Organisation for Economic Co-operation and Development Guidelines for Multinational Enterprises. The expectation to adhere to laws and regulations is outlined in our Code of Business Conduct.

If employees identify illegal activity or activity in violation of the Code of Conduct, they should report those violations to their management or a representative in the Human Resources, Legal or Compliance organizations, or through the Compliance Hotline. Incidents are investigated and corrective actions are taken as necessary according to company policy. Suppliers are also subject to our Code. Additionally, we are working to improve the monitoring and enforcement of human rights in our supply chain through participation in the Pharmaceutical Supply Chain Initiative.

HR5

Operations identified in which the right to exercise freedom of association and collective bargaining may be at significant risk, and actions taken to support these rights.

We have not identified any owned operations where the right to exercise freedom of association and collective bargaining may be at significant risk. We are working to improve the monitoring and enforcement of human rights in our supply chain through participation in the Pharmaceutical Supply Chain Initiative.

HR6

Operations identified as having significant risk for incidents of child labor, and measures taken to contribute to the elimination of child labor.

We have not identified any owned operations at significant risk for incidents of child labor. We are working to improve the monitoring and enforcement of human rights in our supply chain through participation in the Pharmaceutical Supply Chain Initiative.

HR7

Operations identified as having significant risk for incidents of forced or compulsory labor, and measures to contribute to the elimination of forced or compulsory labor.

We have not identified any owned operations at significant risk for incidents of forced or compulsory labor. We are working to improve the monitoring and enforcement of human rights in our supply chain through participation in the Pharmaceutical Supply Chain Initiative.

HR9

Total number of incidents of violations involving rights of indigenous people and actions taken.

This indicator is not material to our business. View our priority issues.

 

Society Performance Indicators

 

Management Approach

We employ robust Corporate Governance practices to ensure we operate responsibly and comply with laws and regulations. Additionally, every employee must comply with our Code of Business Conduct, which guides decision making throughout the organization. In 2010, we updated our Code and required employees to attend live trainings to help them understand the new components. The Code requires compliance with a number of policies, including our Anti-Bribery and Anti-Corruption Policy; Gifts, Bribes and Improper Payments Policy Statement; Global Contract Review Policy; Global Purchasing Policy; Global Travel and Expense Policy; Transaction Approval and Signature Authority Policy. As part of our Anti-Bribery and Anti-Corruption Program, we introduced standardized global operating procedures focused on grants and donations, sponsorships, fees for services and hospitality, and coordinated associated trainings for our employees.

If employees identify illegal activity or activity in violation of the Code of Conduct, they should report those violations to their management or a representative in the Human Resources organization, or through the Compliance Hotline. Incidents are investigated and corrective actions are taken as necessary according to company policy.
Part of our responsibility is understanding and ensuring responsible practices in the communities where we operate. The Biogen Idec Corporate Sustainability Council sets the sustainability vision and strategy for our organization, which includes our impacts on local communities.

SO1

Nature, scope and effectiveness of any programs and practices that assess and manage the impacts of operations on communities, including entering, operating and exiting.

We strive to operate our business responsibly when entering, operating in, and exiting communities. We engage with stakeholders on an ongoing basis to obtain their feedback and insights.  We also execute a number of programs to reduce our environmental impacts and to assist patients, physicians and local communities. If we exit a community, we strive to minimize the impact on employees through relocation and assistance programs.

SO2

Percentage and total number of business units analyzed for risks related to corruption. 

Periodic risk assessments of the company’s business, including risks associated with corruption, are performed. Such assessments determine the areas and operations to be addressed by Compliance and are used to develop the internal audit plan. Risks associated with corruption are also evaluated in determining the scope of work on individual audit projects, and specific anti-corruption audit procedures are performed as appropriate and necessary.

SO3

Percentage of employees trained in organization’s anti-corruption policies and procedures.

In 2010 and early 2011, employees received training on our Code of Business Conduct and have certified that they have read and understand it. The Code covers anti-corruption policies. New hires are also required to certify that they have read and understand the Code.

S05

Public policy positions and participation in public policy development and lobbying.

Read about our public policy participation and positions.

SO6

Total value of financial and in-kind contributions to political parties, politicians and related institutions by country.

Read about our public policy participation.

SO7

Total number of legal actions for anti-competitive behavior, anti-trust and monopoly practices and their outcomes.

Biogen Idec has not had any legal action in the United States for anti-competitive, anti-trust or monopoly practices. In Europe, there have been a limited number of claims challenging Biogen Idec's European inventory quota management system, on national or European Community competition grounds, asserted by wholesalers seeking to exploit arbitrage opportunities arising from the price discrepancies that exist within the single market. We have prevailed in each instance.

 

Product Responsibility Performance Indicators

 

Management Approach

As a biotechnology company, the health and safety of our patients is of the upmost importance. Our Code of Conduct delineates our responsibilities and related policies governing clinical research, drug safety, regulatory excellence, product information and promotion, and interactions with health care professionals and organizations. Every employee is trained on the Code; moreover, individuals with specific responsibilities related to the development and marketing of therapies receive regular additional trainings based upon their functional responsibilities.

The development of our products is overseen by various functions within our Research and Development organization and is headed by our EVP of Research and Development.   

We also strive to be transparent in our marketing communications. Marketing is overseen by our Marketing department, headed by our EVP of Global Commercial Operations. Development of marketing communications includes review by internal Product Review Committees, as well as regulatory bodies, to ensure accuracy and transparency. Finally, through our patient services organization, which also reports to our EVP of Global Commercial Operations, we help patients and their health care providers understand the therapeutic options Biogen Idec offers, as well as provide additional support regarding the emotional, logistical and financial assistance needs that come with living with one of the diseases our therapies treat. 

PR1

Life cycle stages in which health and safety assessed for improvement, and percentage of significant products and services categories subject to such procedures.

The process for development, manufacture, marketing and disposal of our therapies is highly regulated and includes stringent consideration for human health and safety at each step in the process.

PR3

Type of product and service information required by procedures, and percentage of significant products and services subject to such information requirements.

All of our products contain information on the contents and safe use and disposal of the therapies. They do not contain information on how the products are sourced.

PR6

Programs for adherence to laws, standards and voluntary codes related to marketing communications, including advertising, promotion and sponsorship.

Biogen Idec complies with relevant laws and regulations. We comply with the Code of Pharmaceutical Marketing Practices of the International Federation of Pharmaceutical Manufacturers and Associations (IFPMA), The Code of Practice of the European Federation of Pharmaceutical Industries and Associations (EFPIA), as well as local laws and codes of marketing practice, such as the Pharmaceutical Research and Manufacturers’ of America (PhRMA) Code on Interactions with Healthcare Professionals, and our own policies and procedures.

PR7

Total number of incidents of non-compliance with regulations and voluntary codes concerning marketing communications, including advertising, promotion and sponsorship by type of outcomes.

Biogen Idec received a Notice of Violation (NOV) letter from the United States Food and Drug Administration (FDA) in March 2010 and a prior one in March 2009. The NOV in 2009 was for search engine terms. Biogen Idec received an NOV on the same day as 13 other companies. Pharmaceutical companies in totality changed their search engine terms based on the letters FDA sent. The NOV in 2010 was for a webcast focused solely on progressive multifocal leukoencephalopathy (PML). The purpose was to educate prescribers about recent learnings of PML. FDA viewed the webcast as promotional and stated we did not have all required information