Oversight and Implementation. 7.18 Upon the Effective Date of this Agreement, Novartis will immediately commence the process of preparing training for all Employee Relations and Human Resources Business Partner personnel regarding all changes made in accordance with this Agreement. Novartis anticipates the roll-out of training will commence approximately one (1) year later, and the Company will put forth best efforts to commence training even earlier if it is practicable to do so. 7.19 Novartis currently maintains, and will continue to maintain, a database of all complaints that the Employee Relations Group investigates which includes: (i) the date of the complaint, (ii) the type of complaint, (iii) the complainant (where available), (iv) the identity of the subject of the complaint, (v) the investigator assigned, (vi) the date of the initial contact with the complainant, (vii) the outcome of the investigation (unsubstantiated, unable to conclude, or substantiated), and (viii) the nature of the corrective action, if any. 7.20 The investigation file contains: (i) dates of interviews, (ii) date of clarification meeting[s], and (iii) date of Resolution Committee meeting. 7.21 Novartis will build into the investigation process identification at the inception of the investigation whether the subject of the complaint has been the subject of any prior complaints. 7.22 The Head of Employee Relations will compile an annual report to be delivered to the Compliance Committee with one copy to the Chairman of the Novartis Pharmaceuticals Corporation Board of Directors. Each annual report will relay the contents of the databases detailed above, including an assessment of any gender-related trends evidenced in that data, and a summary of the nature and resolution of complaints.
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Sources: Settlement Agreement, Settlement Agreement, Settlement Agreement