Structure and Programs
Baxter designed and updates its Ethics and Compliance structure and programs regularly to reflect the needs of a diversified and complex global healthcare company.
Corporate Responsibility Office
The Corporate Responsibility Office (CRO), established by Baxter’s board in 1993 and composed of six senior executives, is responsible for communicating the company’s ethics and compliance standards, providing guidance and overseeing training to employees and directors, maintaining multiple channels for employees to report concerns and monitoring compliance. The CRO, which meets at least every quarter, reports to the board's Public Policy Committee and reports on financial matters to the board's Audit Committee (see graphic). Baxter was one of the first companies to establish a direct reporting relationship between its CRO and its board, ensuring ethics and compliance oversight at the highest level.
Baxter's Regional Ethics and Compliance Committees implement the CRO's charter globally and enhance corporate understanding of local cultures, values and behavioral norms. Committee membership rotates to ensure broad employee exposure and participation. In 2007, Baxter re-energized the regional committees by creating regional counsel roles in Europe, Asia Pacific and Latin America. One attorney is dedicated to each region. During 2008, these attorneys conducted 17 compliance assessments covering several countries, regions and business units to improve operating and control procedures. They also identified training and educational opportunities, and shared best practices. (See 2007 Case Study: Regional Ethics and Compliance Counsel). Additionally, the ethics and compliance team works closely with Baxter’s global auditing group to ensure compliance issues are part of general business audits.
Certificate of Integrity and Compliance
Each year, Baxter requires mid-level supervisors, sales representatives and other selected employees around the world (almost 25 percent of Baxter's workforce) to reaffirm their commitment to the company's ethics and compliance standards. These employees must complete and submit a Certificate of Integrity and Compliance (COIC), which is available in 11 languages.
The COIC also serves as a reporting document that measures the integration of ethical business practices throughout Baxter. Participation has more than doubled since 2000, as Baxter expanded the number of people required to complete this process.
Legal and Regulatory Compliance Training
Baxter requires employees worldwide to take Web-based training on legal and regulatory compliance. In 2008, 34,634 employees completed 85,444 training courses covering areas such as product complaints, pharmacovigilance, adverse-event reporting procedures, workplace violence prevention, data privacy, healthcare fraud and abuse, trade compliance, requirements for selling to the U.S. government, the Foreign Corrupt Practices Act, antitrust, intellectual property, and Baxter’s ethics and compliance standards. The Ethics and Compliance group also conducted 188 classroom sessions around the world in 2008 to train employees on Baxter’s standards.
In addition, in early 2009, Baxter launched a risk-based anti-corruption education program that provides ongoing training and communication to various groups within the company to sustain awareness. The company plans to build on this education and awareness platform for other key legal risk areas.
Broader Anti-corruption Activities
Because anti-corruption efforts can be impeded or enhanced by others in the industry, Baxter also is committed to establishing or improving industry codes of conduct and ethical behavior across the healthcare industry. For example, Baxter participates in a Eucomed working group that educates physician groups on corruption issues. In 2009, the company will identify industry associations in Latin America and Asia Pacific with which to collaborate to develop and enhance industry codes of conduct. Baxter also is evaluating how broader anti-corruption initiatives such as the UN Global Compact, World Economic Forum Partnering Against Corruption Initiative or the Organisation for Economic Co-operation and Development Principles may complement the company’s approach.
See the Ethical Conduct and Legal Compliance priority update for more information.
