Office of Ethics

Office of Ethics

How we operate is as important as what we do.



It is critically important to patients, purchasers, health care professionals, employees and investors, and to the sustainability of our business success, that we adhere to all applicable laws and regulations, follow ethical business practices, maintain good corporate governance and treat people with respect.

We have strong management oversight, comprehensive corporate policies and procedures, and a long history of abiding by legal and regulatory requirements and promoting high ethical standards. Every employee worldwide is responsible for adhering to business practices that are in accordance with the letter and spirit of the law and with ethical principles that reflect the highest standards of corporate and individual behavior.

Our company’s Office of Ethics was established over 20 years ago to protect and promote the company’s values and standards on a worldwide basis by developing and overseeing global initiatives designed to deter illegal, unethical and improper behavior related to the company’s business. It is responsible for ensuring that employees are aware of and trained on the Code of Conduct and corporate policies.


The Office of Ethics serves as a channel for the receipt and investigation of employee ethical and compliance-related concerns. There are multiple vehicles through which employees can contact the Office of Ethics. Employees can contact the Office of Ethics directly, by a toll-free telephone number or by email, to speak to an ethics officer or ombudsperson. Our company also provides a confidential, toll-free intake service, called AdviceLine, through a third party that offers the option for the reporting person to remain anonymous.

The Office of Ethics is also responsible for managing our Ombuds Program, which offers an additional safe haven for U.S.-based employees to discuss work-related issues without fear of retaliation. This program confidentially addresses employees’ concerns mainly relating to manager or coworker relations or fair treatment.


It is our policy to maintain a work environment where all employees are expected to report ethical and compliance concerns that are potentially inconsistent with the company’s Code of Conduct and policies. Our company is committed to maintaining a process for escalation and investigation of potential- and compliance-related concerns.

Retaliation against employees who report such concerns is a violation of corporate policy and will not be tolerated. The Office of Ethics is responsible for oversight of the global processes for managing investigations into potential ethics and compliance concerns to ensure consistent and timely resolution of potential concerns and implementation of remediation actions. When we substantiate allegations of ethical misconduct, we take appropriate disciplinary actions in order to ensure that those who were responsible are held accountable.

Disciplinary actions can include dismissal from the company, issuance of final written warning letters or financial penalties. We also take appropriate steps to address any needed improvements in organizational and process controls.

We also maintain a policy that will give our company the discretion to recoup incentive payments made to employees in certain instances. This policy will apply when a senior leader engages in misconduct or fails to reasonably supervise an employee who engages in misconduct that results in a material policy violation relating to the research, development, manufacturing, sales or marketing of company products where the policy violation causes significant financial or reputational harm to the company.


An important component of our corporate compliance program is our annual ethics and policy certification. The annual review process requires selected company employees to certify compliance with corporate policies on ethical business practices, antitrust-law compliance, and conflict-of-interest and insider trading. These employees are also expected to regulate their outside activities to avoid any conflicts of interest and certify, in writing, whether actual or potential conflicts of interest exist. Where potential conflicts are identified, the Office of Ethics will work with management to take actions to mitigate the potential conflict. In addition, all U.S.-based employees must certify compliance with our corporate policy on the effects of exclusions, debarments, suspensions and health care–related criminal convictions, reporting and screening.


ETHICAL BUSINESS PRACTICES2012 2013 2014 2015 2016
Employees who responded to disclosure statement on Conflicts of Interest form99% NA 100% 100% 100%
Concerns brought to the company's attention, such as employees seeking ombudsman services (most often relating to manager or coworker relations) and guidance on conflict-of-interest or Code of Conduct issues713 624 517 484 389
Allegations involving noncompliance with company policy investigated1,012 968 1,069 638 479
Ratio of substantiated allegations to concerns/issues raised60% 58% 60% 58% 55%
Employees separated related to substantiated corporate policy violations1166 313 365 156 123
Employees who received written warnings as disciplinary actions resulting from substantiated concern232 269 323 148 137
Worldwide employees represented by an independent trade union or covered by a collective bargaining agreement31% 32% 31% 32% 29%
NA: Not available.
1. This data represents investigations conducted on a companywide basis.