Guidance and Compliance
Open communication is at the core of Baxter’s commitment to integrity, and managers are responsible for maintaining an environment that allows employees to openly raise and discuss issues. Baxter encourages employees to seek guidance and report concerns as needed through any of 10 formal channels (see graphic). Through these channels, Baxter prevents incidents from occurring and addresses issues when they do arise.

One such channel is the Baxter Ethics and Compliance Helpline, a telephone and Web resource available to employees, their families, suppliers and customers. Callers to the helpline can receive live translations in 150 languages, 24 hours a day, seven days a week. Enhancements in 2006 included hiring a third party recognized as a leader in the helpline industry to manage the helpline, and increasing ease of access from anywhere worldwide.
In addition, in 2006 the Certificate of Integrity and Compliance (COIC) process identified 38 issues requiring follow-up by Ethics and Compliance staff, all of which have been resolved.
In 2006, Ethics and Compliance received a total of 341 inquiries through these two channels (see table), 244 of which were related to ethics and compliance. The subjects of the inquiries included gifts and entertainment, sales and marketing practices, conflicts of interest and others.
| ETHICS AND COMPLIANCE HELPLINE AND CERTIFICATE OF INTEGRITY AND COMPLIANCE INQUIRY TOPICS | ||||
| INQUIRY TOPIC | 2003 | 2004 | 2005 | 2006 |
| Assets, Information, Records and Methods of Communication | 52 | 49 | 40 | 63 |
| Bioethics | 3 | 6 | 6 | 11 |
| Conflicts of Interest | 9 | 12 | 9 | 38 |
| Contracting with Third Parties | 29 | 11 | 4 | 15 |
| Customer Relations | 0 | 13 | 4 | 0 |
| Employment Practices | 13 | 17 | 13 | 21 |
| Environment, Health and Safety | 6 | 2 | 4 | 4 |
| Ethics and Compliance Elements | 19 | 22 | 16 | 19 |
| Gifts and Entertainment | 10 | 12 | 19 | 16 |
| Human Resource Concerns | 137 | 104 | 107 | 91 |
| Political Activities and Public Affairs | 2 | 1 | 0 | 2 |
| Prohibition of Corrupt Practices | 6 | 3 | 2 | 10 |
| Providing Information to Governmental Organizations | 0 | 0 | 0 | 3 |
| Quality and Regulatory Compliance | 16 | 15 | 14 | 7 |
| Sales and Marketing Practices | 24 | 17 | 19 | 33 |
| Trade Compliance | 2 | 3 | 3 | 2 |
| Other | 34 | 22 | 14 | 6 |
| TOTAL | 362 | 309 | 274 | 341 |



