Records and Information Management
Records and information are corporate assets and are to be valued and managed accordingly and in compliance with all applicable laws and regulations. Reports, records or other information must be completed fully and accurately, and, if applicable, timely filed with or submitted to the relevant external source. This includes, but is not limited to, external documents, such as financial statements, reports, and other documents filed with, or submitted to the Securities and Exchange Commission.
Inaccurate reporting of information to federal or state governments or organizations or persons outside the Company may lead to criminal or civil liability for any individuals that are involved and the Company. This is the case regardless of whether such statements are made directly or indirectly, orally or in writing, informally or under oath, voluntarily or as a result of a legal requirement. It is considered a crime, even if the Government was not actually misled by the false statement. Inaccurate reporting includes both the failure to provide information needed to make a document complete and not misleading, as well as presenting information in such a manner as to distort its meaning or significance.
False statements cover a wide range of activities, such as making a false or fraudulent representation, concealing a material fact, speaking a half-truth, and promising to do something in the future without any present intention to perform. It is also unlawful when working with any employee of the Federal Government to make or use a document that contains a false statement. Making a false statement is based not only on willfully intending to defraud, but also includes having a reckless disregard for whether a statement is true or a conscious effort to avoid learning the truth.
Staff members who are responsible for reporting, filing and/or submitting reports, records, documents or other information with an external source shall ensure that such reports, records, documents, or other information is accurately and timely reported, filed and/or submitted. Staff members should not sign any document unless they have first determined that the document is accurate and complete. A staff member who believes that inaccurate or dishonest recording or reporting of information has occurred or is occurring should immediately report such activities by calling the Business Conduct Hotline (see the “Where to Turn for Help or Report Concerns” section for contact information).
All records, documents, and information shall be created, retained, and managed in a manner that protects the integrity of the information and at the same time ensures appropriate access. Records, documents, and information shall be retained in accordance with Amgen’s Records Retention Schedule subject to any hold order, laws, or regulations. When a record completes its retention period, it shall be deleted or destroyed in compliance with written procedures, subject to any other provisions of the Corporate Compliance Policy, hold order, laws or regulations. Please refer to the current Records and Information Management Program Policy for additional details regarding the policy and the obligations of individuals subject to the policy.
Every individual who conducts business for or on behalf of Amgen, at every Amgen site worldwide, is required to follow all laws and Amgen policies applicable to him or her, and should exert due diligence in preventing and detecting violations of such laws and policies.
