Structure and Programs
Baxter's Ethics and Compliance structure and programs are designed and routinely updated to reflect the needs of a diversified, complex and international healthcare company.
Corporate Responsibility Office
The Corporate Responsibility Office (CRO), established by the board in 1993, is responsible for communicating Baxter's ethics and compliance standards, providing guidance and 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 the 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 addition, in 2006 Baxter added regional ethics and compliance lawyers to offer additional support and further strengthen the company's ethics and compliance programs in the major regions where it operates. See Case Study: Ethics and Compliance as a Competitive Advantage for a description of how Baxter's ethics and compliance commitments are implemented in practice in Poland.
Certificate of Integrity and Compliance
Each year, Baxter requires mid-level managers and above, sales representatives and other selected employees around the world (almost 25 percent of Baxter's workforce) to reaffirm their commitment to the company's Global Business Practice Standards. To do so, these employees are required to complete and submit a Certificate of Integrity and Compliance (COIC), which is available in 11 languages.
The COIC is also a reporting document designed to measure 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 about legal and regulatory compliance requirements. In 2006, 19,173 employees completed a total of 44,850 modules covering areas such as data privacy, healthcare fraud and abuse, trade compliance, special requirements when selling to the U.S. federal government, the Foreign Corrupt Practices Act, antitrust and intellectual property.
