Novo Nordisk A/S : accepts fine for violating disclosure obligation in Denmark

500,000 fine imposed by the Public Prosecutor in a suit filed by the Danish Financial
Supervisory Authority and detailed in a press release issued by Novo Nordisk on 10
December 2013. In December 2013, the Danish Financial Supervisory Authority reported the company to the police for violating its obligation under Section 27 (1) of the Danish Securities Trading Act to disclose inside information as soon as possible. The reporting concerned the company's receipt of a Complete Response Letter from the US Food and Drug Administration (FDA) in the evening of Friday 8 February 2013. In the letter, the FDA stated that approvals for the insulin products Tresiba® and Ryzodeg® could not be granted on the basis given.
Novo Nordisk published the FDA's decision in a company announcement on Sunday 10
February 2013 following an intensive investigation and evaluation of the implications and impact of the agency's decision. In the opinion of the Danish Financial Supervisory Authority and the Public Prosecutor, Novo Nordisk should have issued a company announcement already on the Friday evening.
Novo Nordisk is of the opinion that the company announcement was issued in a timely manner. The company maintains that even if the disclosure obligation could be said to apply already on the Friday evening, the company was entitled to delay public disclosure until the implications of the decision had been adequately analysed, which they had been on the Sunday. However, for resource reasons Novo Nordisk's management has chosen to accept the fine to avoid a lengthy lawsuit. This will finally settle the case.
On 12 February 2013, NASDAQ OMX Copenhagen launched a similar investigation into whether Novo Nordisk had violated the disclosure obligations applicable to all companies listed on the stock exchange. On 8 May 2013, NASDAQ OMX Copenhagen informed Novo Nordisk that the stock exchange found no basis for concluding that Novo Nordisk had
violated the rules, and that it considered the matter closed.

Corporate Communications

Novo Allé

2880 Bagsværd

Denmark

Telephone:

+45 4444 8888

Internet: www.novonordisk.com CVR no:

24 25 67 90

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Headquartered in Denmark, Novo Nordisk is a global healthcare company with more than 90 years of innovation and leadership in diabetes care. The company also has leading positions within haemophilia care, growth hormone therapy and hormone replacement therapy. Novo Nordisk employs approximately

40,700 employees in 75 countries, and markets its products in more than 180 countries. For more

information, visit novonordisk.com.

Corporate Communications

Novo Allé

2880 Bagsværd

Denmark

Telephone:

+45 4444 8888

Internet: www.novonordisk.com CVR no:

24 25 67 90

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