Code of Conduct

Baxter’s Code of Conduct defines the core principles that govern employee behavior at Baxter and how the company conducts its business. 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.

In 2010, Baxter translated the Code of Conduct into Arabic, making it now available in 21 languages. The Code applies to Baxter's board of directors as well as all employees, including the chief executive officer and other senior officers. 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 of Conduct reflects evolving regulations and industry practices, including Baxter's relationship with healthcare practitioners, medical institutions and patient organizations in the United States and internationally. 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 perceived 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. (See the Ethical Conduct and Legal Compliance priority update for more information.)

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. 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 to conduct business with Baxter (see Managing Supplier Performance for more information).

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.