
and Compliance
Codes and Standards
Code of Conduct
Baxter’s Codes and Standards are designed for employees and also extend to the company’s relationships with suppliers, healthcare practitioners, medical institutions and patient organizations.
Baxter’s Code of Conduct defines the core principles that govern employee behavior at Baxter and how the company conducts its business. The Code applies to Baxter's board of directors, and all of its employees including the company’s chief executive officer and other senior management. It builds on Baxter’s long-standing commitment to leadership in ethical business practices, covering topics such as protection and use of company assets, accurate recordkeeping, competitive and confidential information, sales and marketing practices, anticorruption, insider trading, bioethics, conflicts of interest, gifts and trade compliance. The Code’s user-friendly format includes questions and answers, decision guides and lists of additional resources available to employees to help maintain a culture of integrity throughout Baxter.
As Baxter expands its global presence, the company has increased the number of languages in which its Code of Conduct is available. In 2011, Baxter translated the Code into Slovenian, for a total of 22 languages.
All new Baxter employees receive Code of Conduct training within the first three months of employment. Baxter’s corporate policies support the Code by defining Baxter’s intentions, setting behavioral expectations and requiring certain actions with respect to particular topics. A comprehensive Intranet site provides employees with additional information on corporate policies.
Baxter’s Code of Conduct reflects evolving regulations and stakeholder expectations governing industry practices, and also extends to the company’s relationships with healthcare professionals, medical institutions and patient organizations globally. This includes Baxter’s Global Anticorruption Policy, which covers how the company’s employees, contractors, agents and third parties conduct themselves with government officials. In addition, the Code requires the prompt reporting of suggested misconduct and outlines the consequences of failure to comply with applicable laws or Baxter's policies and procedures. Baxter provides ongoing training and a Code of Conduct website to keep employees up to date on the company’s ethics and compliance policies, topic-specific training and other tools and resources.
Standards for Baxter Suppliers
The company’s Ethics and Compliance Standards for Baxter Suppliers is designed to ensure that all Baxter suppliers also comply with the company’s Code of Conduct. These standards, translated into 20 languages, define policies and set common expectations about ethical behavior when doing business with Baxter. They also define the expected conduct when working for or on behalf of Baxter and are a formal part of standard Baxter supplier agreements. Baxter’s Purchasing and Supplier Management group evaluates and approves all key suppliers before any materials, components, products or services may be purchased. Suppliers must agree to abide by these standards which are incorporated into supplier agreements, to conduct business with Baxter (see Managing Supplier Performance for more information). Additionally, the Baxter Supplier Quality Standard specifically addresses sustainability issues, including indentured and child labor, employment standards, waste and energy reduction, and ethics.
In addition to the standards described above, Baxter has adopted other professional codes of ethics, including:
- AdvaMed Code of Ethics on Interactions with Health Care Professionals;
- Ethics & Compliance Officer Association (ECOA) Standards of Conduct for Business Ethics and Compliance Professionals;
- European Federation of Pharmaceutical Industries and Associations (EFPIA) Code of Practice on Relationships with Patient Organizations;
- Institute for Supply Management (ISM) Principles and Standards of Ethical Supply Management Conduct;
- Professional Society of Engineers Code of Ethics for Engineers;
- Regulatory Affairs Professionals (RAPS) Code of Ethics for Regulatory Affairs Professionals; and
- Society for Corporate Compliance and Ethics (SCCE) Code of Ethics for Compliance and Ethics Professionals.






