Ethics and Compliance Standards

These standards apply to individuals/organisations that provide services, raw material, active ingredients, components, finished goods, or other products (“Suppliers”). Where they exist, the Supplier’s own written ethics and compliance standards may replace these Standards if they are consistent with these standards and are incorporated into a written agreement between Baxter and Supplier.

Adherence to applicable laws and regulations

  • Suppliers must comply with the applicable laws, rules, regulations, and ethical standards of the country in which they operate, applicable U.S. laws, as well as these Standards.

Prohibition of bribes, kickbacks, unlawful payments, and other corrupt practices

  • Suppliers are prohibited from directly or indirectly paying anything of value to a government official in order to:
    • Win or retain business or to improperly influence the act or decision of any government official, political party, candidate for political office, or official of a public international organisation;
    • Gain an improper advantage; or 
    • Illegally influence the action of any individual, customer, company, or company representative. 
  • Suppliers are required to keep accurate and transparent records that reflect actual transactions and payments.
  • While Baxter observes local business customs and market practices, neither Baxter nor any Supplier shall participate in any corrupt, unethical or illegal practices.
  • Suppliers shall not do anything Baxter policies prohibit.

Accuracy of business records

  • All financial books and records must conform to generally accepted accounting principles.
  • Supplier records must be accurate in all material respects.
    • Records must be legible, transparent, and reflect actual transactions and payments.
    • Do not hide, fail to record, or make false entries.

Interactions with healthcare professionals

  • When engaged with healthcare professionals or patients on behalf of Baxter, all suppliers, dealers, distributors, agents and other third parties must adhere to any industry standard of conduct that apply to them (such as AdvaMed and EFPIA Code of Practice).
  • Any payment or benefit provided to a healthcare professional on behalf of Baxter must comply with the policy for the country or region in which the healthcare professional resides and/or practices medicine.

Fair competition and antitrust

  • Suppliers must comply with all applicable laws and regulations regarding fair competition and antitrust.

Intellectual property and confidential information

  • All Suppliers requiring the exchange of confidential information with Baxter are required to execute a confidentiality agreement with Baxter in advance.
  • Exchange of confidential information is limited to that required to fulfill contracted performance requirements.
  • Suppliers shall not share Baxter’s intellectual property or confidential information or any other information that they acquire with respect to Baxter’s business (including information developed by Suppliers and information relating to products, customers, suppliers, pricing, costs, know how, strategies, programs, processes, and practices).
  • Suppliers must immediately report unauthorised disclosure of Baxter’s confidential information, whether inadvertent or not, through the Ethics & Compliance Helpline.

Data Privacy

  • Supplier must abide by applicable data privacy laws and regulations when handling personal information.
  • Suppliers must immediately report unauthorised use, disclosure, or loss of Baxter related personal information through the Ethics & Compliance helpline.

Employee Practices Guidelines

  • Suppliers must treat Baxter employees with dignity and respect.
  • Suppliers must comply with all applicable Employment laws and regulation including statutes prohibiting discrimination in the workplace.
  • Suppliers shall not possess, use or sell illegal drugs on Baxter property or perform their work under the influence of alcohol or illegal drugs.
  • Suppliers will not produce or manufacture goods or services using forced or indentured child labour.
  • Regular full-time employees are to be at least 18 years of age. Suppliers must disclose the existence of part-time work, summer jobs, or apprenticeship programs for individuals under the age of 18 to Baxter's management.
  • Baxter does not permit intimidation or hostility and will not tolerate any behaviour from a supplier that might harass, disrupt or interfere with another person’s ability to work.

Conflicts of interest

  • A conflict of interest arises when personal interests or activities influence, or appear to influence, the ability to act in the best interests of Baxter. Some situations that could cause a conflict of interest include:
    • Having a significant financial investment in any company that competes, does business, or seeks to do business with Baxter. A significant financial interest includes voting control, or an ownership of more than 1% of the outstanding capital of a business, or an investment that represents more than 5% of the investor’s total assets.
    • Providing similar services for direct competitors of Baxter, with access to confidential or competitive information.
  • When family members (or domestic partners, or those personally close to you) work for Baxter, another Baxter supplier, Baxter customer or Baxter competitor.
  • Suppliers must disclose any apparent or actual conflicts of interest to Baxter's management. If Baxter management approves an apparent or actual conflict, the approval decision must be documented.

Mobile devices, electronic media, internet and e-mail use

In those circumstances where Suppliers have access to Baxter’s electronic environment (Intranet, e‐mail, voicemail or other), Suppliers shall:

  • Protect Baxter’s confidential information and electronic media;
  • Encrypt or password protect data;
  • Keep mobile devices with you or locked while travelling;
  • Comply with local data protection laws;
  • Use these tools for Baxter business purposes only; and
  • Use these tools consistent with Baxter’s Global Acceptable Use of Information and Technology Policy including:
    • Do not knowingly download, view or forward materials of a discriminatory, harassing, threatening, sexual, pornographic, racist, sexist, defamatory or otherwise offensive nature. Electronic media must be primarily used for business purposes.
    • Do communicate protected information (personal or trade secret) in a way that recognises the sensitivity of the information, possibility of unauthorised access, and compliance to local data protection laws. Suppliers will be responsible for keeping Baxter-given password(s) secret.
    • Realise that documents, software, e-mails and other web pages could bring damaging computer viruses into Baxter’s network. Do not knowingly detach, decompress, run/launch or install any files or programs on Baxter’s systems or open attachments that have damaging computer viruses. Do not download or disseminate any material from the Internet unless the copyright owner has provided consent.
    •  Adhere to the timing and methods for retention and elimination of Baxter company data stored on electronic media.

Trade Compliance

  • Suppliers must comply with the letter and spirit of all applicable import and export controls, sanctions, and other trade compliance laws of the United States and the laws of the applicable country(ies) where the transaction(s) occur(s).

Environment, health and safety

  • Suppliers are expected to comply with all applicable laws and regulations regarding environment, health and safety.
  • Suppliers working with Baxter or onsite at a Baxter location must work in a way that assures their own safety and the safety of others and in compliance with applicable Baxter and governmental environmental, health and safety requirements. Any emergencies that may impact Baxter must be reported promptly.

Gifts and Entertainment

Gifts and entertainment are not needed in order to conduct business with Baxter and are highly discouraged.

  • The following situations are always inappropriate and are expressly prohibited:
    • Giving a gift, entertainment, or preferred treatment with the intention of trying to influence the decision making objectivity of a Baxter employee.
    • Offering any gift, entertainment, or preferred treatment while involved in a current purchasing or contracting decision process. (RFI, RFQ, RFP).
    • Any gift of currency including “gift cards”.
    • Offering entertainment where the Supplier will not be present/represented (e.g., sports/event tickets).
    • Offering extravagant recreational outings, travel, or lodgings at supplier sponsored events.
  • On a rare and infrequent basis Baxter employees may accept very modest gifts, entertainment, or other business courtesies if it helps improve the business relationship and they would be able to reciprocate in equal value.
  • Baxter employees are not permitted to solicit suppliers for gifts including gifts to support charitable causes.
  • Suppliers shall not offer an opportunity to purchase products, services, or a financial interest to any Baxter employees under terms not available to all Baxter employees.

Resources

  • If you need additional information or guidance on these standards, or wish to report a potential violation, contact Baxter's Ethics & Compliance Helpline.
  • Additional supplier information can be found at www.baxter.com

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