Ethics and Compliance

As a global healthcare company operating in more than 100 countries, we are committed to effective corporate governance, adherence to the law, and a culture of ethics and compliance throughout the organization. In 1995, we became one of the first companies to adopt formal corporate governance guidelines. Enhancing our practices and setting new standards is ongoing, and our current corporate governance guidelines reflect this evolution.

Our Ethics and Compliance team works closely with operating and legal teams based across the regions in our businesses to ensure that our activities adhere to applicable laws and to company policies. We offer numerous channels to educate and counsel employees, as well as confidential avenues to raise questions or report alleged violations of law and company policy. We investigate these items promptly and reports to senior management as appropriate.

Codes and Standards

Code of Conduct

We have established a strong foundation of integrity and compliance that helps guide employees in making good, ethical business judgments and taking appropriate, lawful actions.

Read our Code of Conduct >

Standard for Suppliers

We expect suppliers and business partners to comply with our guidelines and to know and obey all the laws governing the purchasing function at Baxter.

Learn more about Supplier Standards >

Human Rights across the Value Chain

As outlined in our Global Human Rights Policy, we respect the human rights, dignity and diverse contributions of all individuals. Fostering human rights in our direct and indirect actions takes many forms, and is reflected in numerous company policies and initiatives, in areas including employment practices, privacy, safety, supply chain, ethical conduct and access to healthcare.

Professional Codes of Ethics and Industry Standards

We have adopted the following external professional and industry codes of ethics:

• AdvaMed Code of Ethics on Interactions with Health Care Professionals
• National Society of Professional Engineers Code of Ethics for Engineers
• MedTech Europe Code of Ethical Business Practice

Additionally, we work with non-governmental organizations and trade associations to enhance ethics and compliance standards worldwide. This includes:

• Working with the China Association of Enterprises with Foreign Investment R&D-based Pharmaceutical Association Committee (RDPAC) on an industry-wide ethical sales and marketing code
• Participating on a task force of the China Council of Advanced Medical Technology Association (AdvaMed) to develop an industry code of conduct for the China operations of AdvaMed member companies
• Working with the Mexican Association of Innovative Medical Devices Industries (AMID) to update AMID’s Code of Interactions with Healthcare Professionals
• Supporting AMID by creating a harmonized training that endorses standards and criteria agreed upon by the medical device industry
• Participating in The Pharmaceutical Supply Chain Initiative

Ethics and Compliance Structure and Programs

We design and update our ethics and compliance structure and programs regularly to reflect the needs of a complex global healthcare company.

We have an integrated local governance model in place, with Ethics & Compliance committees operating at the regional, country and business levels to drive the integration of the Ethics & Compliance program throughout Baxter.

Trade Compliance

We have a global network of personnel tasked with identifying and addressing trade compliance issues in their countries and functions, and seeking advice from designated subject matter experts as warranted. We also continue to enhance tools and processes to screen for and address related risks involving our products and business transactions.

Data Privacy and Security

Our Global Privacy Policy defines our privacy standards and guides our global operations to follow similar controls for protecting personal and patient health information. All Baxter employees are required to complete an online privacy training course.

Communication and Guidance

Open communication is central to our commitment to integrity. We offer numerous channels to educate and counsel employees, as well as confidential avenues to report suspected violations of law and policy, which it investigates promptly and reports to senior management as appropriate. Managers are responsible for maintaining an environment that enables employees to raise and discuss issues safely.

One such channel is the Baxter Ethics and Compliance Help Line, an independent telephone and Web resource available to employees and their families, suppliers, customers and other Baxter stakeholders to raise issues and openly communicate about possible company ethics and compliance issues. Callers can report an issue or seek guidance in any one of 32 languages, 24 hours a day, seven days a week, and may choose to remain anonymous.