Code of Conduct

In January 2009, Baxter reinforced its commitment to maintaining a culture of integrity when it issued a new Code of Conduct to all Baxter employees, replacing the company’s former Global Business Practice Standards. The company chose to change the title from “Global Business Practice Standards” to “Code of Conduct” to reflect language that has become more standardized and customary in this area. The Code of Conduct defines the core principles that govern employee behavior at Baxter and how the company conducts its business. The updated Code of Conduct reflects changes in industry practices and provides a user-friendly format, with supporting questions and answers, decision guides and lists of additional resources available to employees.

Baxter's Code of Conduct is available in 20 languages and applies to Baxter's board of directors as well as all employees, including the chief executive officer and other senior officers. All employees will participate in mandatory online or classroom training during 2009 to ensure they understand the Code of Conduct and its updated content.

The new Code of Conduct builds on Baxter’s longstanding 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, anti-corruption, insider trading, bioethics, conflicts of interest, gifts and trade compliance. Sections that were expanded or updated based on changes in regulations and industry practices include those dealing with Baxter’s relationships with healthcare practitioners, medical institutions and patient organizations in the United States and internationally, and Baxter’s Global Anti-Corruption Policy, which covers how the company’s employees, contractors, agents and third parties conduct themselves with government officials. (See the Ethical Conduct and Legal Compliance priority update for more information.) The Code of Conduct also 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’s Ethics and Compliance Standards for Baxter Suppliers defines policies and sets common expectations about ethical behavior when doing business with Baxter. Baxter’s purchasing and supplier management group evaluates and approves suppliers before any materials, components, products or services may be purchased. Baxter includes these standards in contracts used during all supplier and contractor negotiations (see Managing Supplier Performance for more information).

In addition to the standards described above, Baxter has adopted the following professional codes of ethics: