Introduction
Abbott
Code of Business Conduct
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Letter from CEO
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Dear Colleague,
Our purpose as a company is as straightforward as it is important: we’re here to make things better, plain and simple.
We create life-changing health technologies that help people live better, fuller lives. It’s a privilege to do this work – and we need to do it in a way that lives up to the nobility of our purpose, with the highest and most ethical of business practices.
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To help all of us do so, Abbott maintains a strong Code of Business Conduct. Our Code lays out our values and our principles, so every Abbott person around the world understands the expectations and requirements that guide the actions we take on Abbott’s behalf.
Letter from CEO
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The fundamental message of the Code is clear: it’s up to us, as the people of Abbott, to hold ourselves to the highest standards, to live up to our best ideals, and to operate our business with the utmost integrity at all times. Our Code is here to help us do so and to protect our most valuable asset as an organization – our reputation.
Thank you for giving our Code of Conduct your careful attention, for using it to help you make the best decisions in your important work, and for all you do to make Abbott the great and good company that it is.
Best regards,
Robert B. Ford
Chief Executive Officer
Our Code in Action
The promise of our company is in the promise that our work holds for health and life, and we live that promise through the actions we take each and every day
Honesty, Fairness and Integrity
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Honesty, Fairness and Integrity
It is up to every person working for Abbott – at all levels of the organization – to uphold the Abbott values (Pioneering, Achieving, Caring and Enduring) and operate with honesty, fairness, and integrity. Abbott’s long-term success depends upon the choices we make every day. We are all responsible for understanding how this Code applies to our work and decision-making, operating at all times in line with this Code, and for promoting compliance with this Code by others operating on Abbott’s behalf. The fundamental message of the Code is straightforward: It’s up to each of us, as Abbott employees, to build our company and our brand by holding ourselves to the highest ethical standards and by operating with honesty, fairness, and integrity.
Decision Making
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Decision Making
Abbott is a global company. We conduct business in over 150 countries around the world and our employees are citizens of many nations with diverse cultures and beliefs. We must recognize the global impact of our actions and decision making and realize that Abbott is subject to many laws, regulations, and other requirements that vary across the countries in which we operate.
Decision Making
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Each of us will, at times, be faced with situations where the right course of action about a new situation is hard to determine. We are all expected to understand the Abbott principles embodied in this Code, along with the Abbott policies and procedures applicable to our work. Many additional resources are available at Abbott for advice and guidance, including:
- Colleagues
- Managers and supervisors
- The Office of Ethics and Compliance
- Human Resources
- The Legal Division
These resources can help guide decision making. Our decision making AID is also available to help work through issues when the best path forward is not obvious. This tool provides an approach to thinking through the alternatives to, and impacts of, decisions we may face in our work.
In addition, help is always available to ensure understanding of this Code’s requirements. General assistance and contact information for your local or regional Office of Ethics and Compliance personnel is available on the OEC website.
Our Customers
We improve health for patients, consumers, and communities
Patients and Consumers
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We prioritize the health and well-being of patients and consumers.
We are passionate about helping people lead healthier lives. Each and every day, we have the opportunity to improve people’s lives and create healthier societies through our work. Caring for people is fundamental to what we do, and it is both a tremendous privilege and a great responsibility.
Health Care Professional Judgment
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We respect the expertise of health care professionals who provide guidance about health care treatment options and healthy living.
Health care professionals, such as physicians, pharmacists, nurses, researchers or laboratory staff, must use their independent judgment to decide the best course of care for their patients based on their training and expertise. We are committed to working with health care professionals to provide them with timely and accurate information to assist them in making decisions and providing advice to their patients. We can achieve our mission of supporting health only through a truly collaborative approach.
Our Products
We earn Abbott’s positive reputation by consistently delivering high quality products
Product Quality
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We produce and deliver safe, effective products that people trust.
We endeavor to maintain the highest level of quality throughout our business. This effort starts with the sourcing of materials and the manufacture of our products and moves through how we market, sell, and supply our products, including through our business partners – delivering high quality is imperative every step of the way.
Product Quality
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Our commitment to the health and safety of the people who use our products is always at the forefront of everything we do.
We are committed to timely identifying, evaluating, and addressing product safety issues. We provide health care professionals and institutions with the information they need in order to use Abbott’s products safely and effectively, and we communicate with regulatory or public health agencies in the event of potential safety concerns.
We take action to prevent counterfeiting, illegal diversion, and theft of our products. We adhere to all applicable trade regulations, such as export and import controls issued by governments for foreign policy and national security reasons. Trade regulations include sanctions, restrictions on exporting of certain products, and prohibitions on conducting business with certain individuals, groups or entities.
Product Promotion
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We promote and sell our products with honesty and integrity.
Our statements about our products, in all materials and communications, will be balanced and truthful and consistent with the approved label. In promoting our products, we provide information that is consistent with scientific evidence, leading medical practice, and the approved product labeling requirements in the countries where we operate.
Product Promotion
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We promote our products for the purposes for which they are intended and approved.
Abbott’s activities conform to the regulatory licenses and approvals we obtain from government agencies such as Ministries of Health, or Food and Drug authorities, to promote, sell, and import pharmaceuticals, medical devices, and other products. We comply with each country’s laws and regulations that govern how, where and when we are permitted to promote our products, such as the United States Federal Food, Drug, and Cosmetic Act. We maintain and follow internal policies and procedures designed to ensure compliance with such requirements and with respect to government health care programs.
Advancing Science
We advance science, technology, and product innovation to work toward a healthier future
Innovation
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We innovate and advance health care solutions and product innovations to improve health outcomes around the world.
We address human needs by pioneering innovative treatments and products, lifesaving medical devices, and new approaches to managing health. We advance leading-edge science, technology, and product innovations to foster improvements to health. Good health is key to our customers maximizing their full potential. We support patients’ and consumers’ pursuit of health throughout the continuum of life, providing innovative products designed to help people live the healthiest, fullest lives possible. We focus on innovation of products that change lives for the better.
Innovation
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We foster a culture of innovation, seek new possibilities, and plan for contingencies.
Our relentless drive toward innovation and new possibilities comes with risk. While we take measured risks that are consistent with this Code and our policies, we should always make efforts to mitigate risks in advance, considering possible outcomes, and plan accordingly.
Advancing Science
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We conduct research to obtain and provide objective, accurate data that will advance science.
We conduct research to advance the science behind our products: to develop new products, improve existing treatments, and advance health care practices.
Advancing Science
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When we conduct research, we are committed to treating study participants with dignity and respect, and to protecting them from unnecessary risk. We ensure that patients participating in research understand the nature and purpose of the research and the associated risks. Obtaining informed consent from study participants is an essential part of our research process.
We value transparency in scientific research, and will not attempt to improperly influence the outcome of any research or reports made by clinical investigators or other researchers. We recognize the importance of ensuring that data from studies and related analyses are accurate. We are committed to providing research results relating to our products, whether results are positive or negative, in a timely and accurate fashion.
When research is done for Abbott or published on our behalf, we select partners with strong medical and scientific backgrounds. We have high standards for these partners, such as expecting investigators to appropriately disclose their connection to Abbott. When we partner with other scientists or clinicians in connection with research and development work, we are committed to complete and accurate disclosure of financial or other relationships.
Our People
We value our diverse perspectives as a source of strength
Collaboration
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We foster a culture of openness, recognizing that diversity of thought and collaboration drive innovation.
We embrace diversity because we believe that it generates creativity, innovation, and energy. We understand that to make a difference and address a wide spectrum of changing health needs, it takes a relentless drive and a collaborative approach, listening to our colleagues and ensuring that all voices are heard.
Our Connection to Each Other
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Our Connection to Each Other
We all share in the responsibility to live our values every day. By demonstrating and supporting ethical behavior, we positively impact the culture of Abbott. We are all responsible for understanding how this Code applies to our work and the role we perform in the company.
Managers and supervisors, as leaders in the organization, must demonstrate a strong commitment to our values and lead by example. They must always promote and support ethical behavior by employees. Managers must help ensure that employees understand their responsibility to abide by this Code and must foster a work environment that allows employees to feel comfortable asking questions and voicing concerns without fear of retaliation.
Reporting Concerns
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We ask questions whenever choices or actions related to our work are unclear or do not seem right, and we speak up and report any violations of this Code.
It is up to each of us to ask questions whenever we feel direction is unclear, and to challenge and report any suspected unethical business conduct, violation of this Code, or violation of our policies or procedures.
Asking questions, reporting concerns, and actively pursuing clarity about our choices or actions helps us identify and avoid problems more effectively. When in doubt about the right choices, actions or potential violations, ask a manager or the Office of Ethics and Compliance.
Reporting Concerns
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Managers and supervisors have a fundamental responsibility to lead by example and ensure that employees understand and are held accountable to the Code. Those in leadership roles carry heightened responsibility for understanding and communicating Abbott’s expectations, and should contact the Office of Ethics and Compliance regarding potential Code violations.
All reports of potential Code violations will be taken seriously and handled appropriately through follow up steps such as investigation, remediation, and where necessary, corrective actions to address issues, learn from mistakes, and avoid recurrence. The Office of Ethics and Compliance will direct any investigation of alleged violations of the Code. You should not conduct any investigation independently. Each of us is required to cooperate in, and maintain the confidentiality of, any such investigation.
Corrective actions related to Code violations may include disciplinary action (up to and including termination), or legal action for:
- Authorization of or participation in a violation;
- Refusal to cooperate in the investigation of an alleged violation;
Reporting Concerns
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- Failure by a violator’s supervisor(s) to detect and report a violation, if such failure reflects inadequate supervision or lack of oversight;
- Reporting a concern that is knowingly false, or is intended to threaten, intimidate or retaliate against any person associated with Abbott’s business;
- Retaliation, such as by intimidating, threatening, harassing or maligning any person who has reported a violation or potential violation in good faith.
It is never acceptable to retaliate against anyone who raises concerns about whether business activities are in line with the Code. Alleged retaliation should be reported to the Office of Ethics and Compliance or Human Resources.
Our commitment to the work that we do drives us to not just follow the letter of the laws that apply to our work, but to be mindful of the ethical expectations that come with being a leader in a business like ours.
Equal Opportunity
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We provide equal opportunities for all employees.
We base employment decisions on business needs, skills, experience, and relative work performance. Abbott prohibits discrimination based on race, color, religion, creed, age, sex, national origin, gender identity or expression, sexual orientation, disability, marital status, veteran or military status, genetics or citizenship status, or any other legally protected status. We are committed to following the laws impacting our relationship with our employees around the world.
Fair Treatment
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We strive to ensure that everyone working at Abbott feels welcome, supported, and inspired to succeed.
Abbott cares about and is concerned for the health and well-being of its employees worldwide. Everyone who works at Abbott should encounter a professional environment, free from intimidation and harassment. Abbott encourages input from its employees on ways to enhance the inclusive and diverse atmosphere of its workplaces and promotes a workplace that is free from disruptive conduct by employees.
Fair Treatment
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We treat everyone with respect and dignity.
Our respect for people is demonstrated in what we do and how we act toward everyone we encounter in our work. To meet our commitments to one another, and to attract, cultivate and retain talented individuals from around the world, it is vital to have a work environment built on mutual trust, respect, and the principles embodied in this Code. We must treat others equitably and not take advantage of others through manipulation, misrepresentation, or concealment.
Work Environment
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We take care to ensure workplace safety and appropriate conditions for employees and others who work for us.
Accidents and unsafe situations must be promptly reported to management. We also take steps to prevent and prohibit illegal and inappropriate labor conditions, and cruel or inhumane treatment, in connection with our business activities around the world.
Our Communities
We build trust in Abbott as a citizen of each local community and the world
Community Involvement
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We strive to foster community well-being through our products and our work.
We have a distinguished history of supporting the communities where we live and work. We believe that with good health, communities can thrive. Through our operations, business relations, and support of community groups and charitable causes, we give back to our communities and our neighbors. In communities large and small, wherever we do business, Abbott strives to make a positive and lasting difference in people’s lives.
Environmental Responsibility
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We engage in sustainable development and endeavor to minimize our impact on the environment.
We are committed to minimizing our global environmental impact, from the responsible sourcing of raw materials to the manufacture, distribution and use of our products.
We take steps to reduce our use of energy and other natural resources. We support projects that generate energy from renewable sources at work and in our communities. We seek ways to reduce the environmental impact of our operations, such as through waste reduction and recycling and other activities to mitigate environmental risks. We adhere to the environmental laws and regulations applicable to our operations.
Political Contributions
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We encourage appropriate engagement in the political process and support community involvement.
Abbott works to support public policy that aligns with our mission and values and, where appropriate, may provide support to political candidates or interest groups. The laws related to political contributions by companies are complex, so it is important that contributions of Abbott funds and any other contributions provided on behalf of Abbott be made only after consultation with the Legal Division.
How We Operate
We work together with accountability and in keeping with Abbott values
Fair Dealing
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We conduct business ethically and honestly, and strive to do what we say we will do, in all aspects of our work.
We are each accountable for our work and decision-making within the realm of our roles and responsibilities.
In all of our professional interactions, with all of the people we encounter in our work – coworkers, customers, suppliers, health care professionals, competitors, and others – we must be fair and straightforward about how Abbott conducts business. This principle of fair dealing is critical.
Avoiding Conflicts of Interest
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We address and resolve any conflicts of interest before moving forward.
A conflict of interest exists whenever an Abbott employee’s private interests interfere, or appear to interfere, with Abbott’s interests. Business decisions should be based on Abbott’s needs, rather than potential personal gain or the interests of family or friends. Each of us is expected to use good judgment and to avoid situations that can lead to an actual conflict or the appearance of a conflict.
If competing actions, interests, or relationships make it difficult to perform your work objectively and effectively, or if you or a family member could receive improper personal benefit as a result of a position with or connection to Abbott, you must disclose the potential conflict of interest in accordance with Abbott’s conflict of interest guidelines and excuse yourself from situations where the conflict could impact your business judgment.
Avoiding Conflicts of Interest
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We place the interests of Abbott above personal interests when making decisions in connection with our work.
The interests of the greater organization should be prioritized over the interests of a business division, a working group, or an individual in the context of our work.
Our positions at Abbott and opportunities, such as outside business deals or financial interests, made available through work activities, should only be used for Abbott’s benefit, and not for personal gain. We should not compete with Abbott or help other individuals or businesses do so. Our priority must be to advance the company’s interests when opportunities arise.
Protection of Abbott Assets & Reputation
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We are caretakers of our company in our work.
It is our responsibility to protect and use Abbott’s assets, from physical property, like vehicles and computer equipment, to intellectual property, trade secrets, and know-how, with care and ensure their efficient and proper use. We must all use good judgment to ensure that Abbott’s assets are not lost, stolen, misused, or wasted.
Protection of Abbott Assets & Reputation
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Abbott’s reputation is one of its greatest assets. We are each responsible for enhancing and protecting Abbott’s reputation. We are each personally accountable for any views or content published or shared with people outside the company.
In external interactions, we need to be mindful of whether we can be identified as affiliated with Abbott, and consider how any statements related to our work may reflect on the company. This is especially crucial in the context of social media where interactions are quick and dynamic and can become highly visible. Careless communications can pose a significant risk to Abbott’s reputation. We are all responsible for employing careful communication strategies in our communications and protecting Abbott’s confidential information.
Confidential Information
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We respect and safeguard confidential information, including personal information.
One of Abbott’s most valuable assets is its confidential information. Confidential information is information that is not publicly available and includes research and development projects, trade secrets, business plans, manufacturing formulas and processes, supplier or customer contract terms, pricing, sales figures, bids, quotes, pricing proposals, responses to tenders, and non-public financial results, or any other information that might be of use to Abbott’s competitors or harmful to Abbott if disclosed.
Each of us must be vigilant to safeguard confidential information and prevent unauthorized disclosure or use. Confidential information should not be shared with competitors. These obligations may extend beyond employment with Abbott.
Similarly, we respect the intellectual property rights of others and will not inappropriately obtain or misuse their confidential information.
Confidential Information
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Misuse of specific confidential information is prohibited by law, such as laws prohibiting insider trading based on non-public information. Insider trading is both unethical and illegal, and we must not buy or sell securities of Abbott, or of other companies doing or expected to do business with Abbott, based on such information.
We respect the privacy of those who entrust their personal information to us, including our colleagues and the people who recommend, prescribe, and use our products. When we collect personal information in the course of our business, we appropriately inform the people whose information we collect about how it will be used, and obtain appropriate consent or authorization. We do not sell personal information or obtain personal information from sources that do not have authorization.
We protect personal and sensitive information from unauthorized disclosure and use. Many locations have strict regulations requiring companies to protect personal information collected and used in the course of business, especially for the most sensitive categories of personal information, and we are committed to understanding and following these requirements.
Anti-Bribery
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We actively oppose fraud, bribery, and corruption. We get business the right way.
As patients, family members and care givers, we want our doctors, nurses and pharmacists to recommend the products and treatments that will best suit our needs, using their professional judgment. Patients and consumers should be able to rely on the independent judgments of their health advisors, without concern that those judgments have been improperly influenced by incentives from companies seeking to promote their products.
As citizens, we want our government officials to make decisions that serve the best interests of the people. Such government decisions should not be improperly influenced by companies seeking favor for their corporate interests through incentives to government officials.
Anti-Bribery
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As we market and sell our products, we educate and inform health care professionals, but do not interfere with their independent, professional judgments. It is never permissible to offer or provide anything that directly or indirectly benefits a government official, a health care professional (such as a physician, pharmacist, nurse, researcher or laboratory staff), or any other person, in order to make a sale or secure a business advantage for Abbott. Similarly, it is never acceptable to provide anything of value as a “reward” for any past or existing relationship with Abbott.
Anti-bribery, anti-corruption, and “anti-kickback” laws make it especially important that we demonstrate our commitment to preventing improper influence in business transactions in all of our interactions. The U.S. Foreign Corrupt Practices Act and other relevant country laws in these areas potentially apply to Abbott’s activities around the world, and bribery is illegal everywhere.
Everyone at Abbott must proactively manage relationships with service providers (such as distributors, consultants, speakers or promoters) to ensure that services performed on Abbott’s behalf are carried out in accordance with our expectations and in compliance with applicable laws and regulations. We must use due diligence when selecting service providers, pay fair market value for services, and accurately document payments for services, fines, fees and the like.
Gifts, Meals & Entertainment
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Gifts, Meals and Entertainment
Because anti-bribery principles require that we never offer or provide anything that directly or indirectly benefits any person to secure a business advantage, we set limits surrounding gifts, meals and entertainment. Our policies and procedures related to limits on and reporting of brand reminders, gifts, cultural courtesies, meals and hospitality are in place to help ensure that we do not provide any benefit that could interfere with professional judgment.
Accurate Books and Records
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We measure achievements accurately.
Our financial books, internal records and documentation, and public statements must accurately reflect the substance and facts of our actions. When we are measuring or describing our successes, failures, and routine operations, the facts must be presented in sufficient context and with adequate support to understand the true nature of our activities or transactions. Our financial records must conform to applicable accounting standards, laws and regulations, as well as Abbott’s policies, procedures and controls.
When we report information, such as pricing or payments and items of value provided to physicians and other customers, the information must be complete and accurate. Many governments around the world have strict laws regarding price reporting and reporting of certain payments to health care professionals. These laws help protect taxpayers, who ultimately pay for some or all of the purchases within the health care system. Abbott is committed to ensuring that we provide accurate information to allow governments, insurers and other stakeholders to make informed decisions.
Compliance with Laws
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We adhere to all laws, regulations and Abbott requirements that apply to our work.
Every Abbott employee is expected to adhere to all laws and Abbott’s policies, procedures, principles and standards, including this Code. This is a fundamental expectation and condition of employment.
Compliance with Laws
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Abbott’s policies and procedures cover topics related to important aspects of our operations, including health care compliance, quality, engineering, customs and trade, finance, security, purchasing, human resources, and information systems, to help ensure that we comply with the many laws and regulations governing our business. Such policies and procedures enable us to detect, correct and prevent non-compliant activities.
As employees of a global company, we must keep in mind that the laws of one country may apply to the way we work in other countries. We must be mindful of the requirements for each location, and seek guidance from the Legal Division or the Office of Ethics and Compliance whenever we face a question about which requirements apply.
Fair Competition
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We ensure that any interactions that we have with competitors are appropriate.
We must compete aggressively in the marketplace to best serve our customers’ needs and enhance shareholder value.
Fair Competition
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In doing so, we will not engage in agreements or activities that unfairly limit competition. We are committed to complying with competition laws in every country where we do business. These laws prohibit agreements that eliminate or discourage competition and apply to many aspects of our business, including relationships with competitors, prices and terms of sale to distributors and other customers and marketing and trade practices. Competition laws are very complicated and penalties for violation may include high fines and even imprisonment. It is important that you do not engage in any activity that could be viewed as anticompetitive, and consult with Legal or the Office of Ethics and Compliance if you have questions.
We must always exercise caution when interacting with competitors. You should not discuss sensitive business topics such as prices, sales terms, business or marketing plans, margins, costs, production capacity, inventory levels or discounts with competitors. You should contact Legal or the Office of Ethics and Compliance for specific guidance about the laws relating to your interactions with competitors and to report any inappropriate conversations with competitors.
Applicability
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Applicability
This Code applies to all officers and employees of Abbott, in all locations where Abbott’s divisions and affiliates operate around the world. This document sets forth the actions expected from all of us, including outside entities acting on Abbott’s behalf, whenever conducting business for Abbott; it is not a contract of employment.
Waivers & Amendments
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Waivers and Amendments
Abbott will make public disclosure, to the extent required by applicable laws, rules and regulations, of any waivers of, or amendments to, this Code.
Any waiver of this Code for a person covered by this Code may be made only by the Chief Executive Officer (or designee), except that a waiver for an Executive Officer requires approval by the Audit Committee of the Abbott Board of Directors.
Resources for Abbott Employees
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Resources for Abbott Employees
Manager or Supervisor
If you have questions on how our Code of Business Conduct applies to your specific job role, the best place to start is with your immediate manager or supervisor.
Abbott Corporate Policy Portal
For our corporate policies and procedures applicable companywide, visit the Abbott Corporate Policy Portal.
Office of Ethics and Compliance (OEC)
The OEC is a corporate resource available to address your questions or concerns about our company’s values and standards of conduct.
- OEC Website – Refer to the OEC website for answers to a variety of ethics and compliance questions. Our company’s global and country-specific OEC policies and procedures can also be accessed from the website.
Resources for Abbott Employees
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OEC Contacts – You are encouraged to contact the OEC at any time with any ethics and compliance questions, or to discuss concerns about possible violations of our written standards, laws, or regulations.
- Corporate OEC – Call 1-224-667-5210 or email oec@abbott.com with any questions related to ethics and compliance at Abbott.
- Divisional or Country OEC – Your divisional or country OEC representative can provide additional guidance on divisional or country-specific OEC policies, procedures, and guidelines.
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Ethics and Compliance Helpline – Visit our multilingual Ethics and Compliance Helpline available globally 24/7 to voice your concerns about a potential violation of our company’s values and standards of conduct. You can also email investigations@abbott.com to report a potential violation.
- Abbott does not tolerate retaliation against anyone who makes a good-faith report regarding a potential violation of our written standards. In any good-faith report, anonymity is allowed, non-retaliation is ensured, and confidentiality is preserved.
- iComply – Visit iComply to access compliance-related applications and resources geared towards interactions with Health Care Professionals and Health Care Organizations, as well as third parties.
Legal Division
If you have questions about the laws, regulations, and acceptable business practices, the Legal Division can assist you.
Resources for Abbott Employees
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Human Resources
For employee-related issues, such as concerns involving management and/or other employees, contact your local Human Resources representative.
Other Resources
There are many other resources available to you:
- Finance – If your question is about accounting or finance, contact your local Finance department.
- Corporate Audit – If you have specific concerns regarding accounting, internal accounting controls, or auditing matters, promptly report them to Corporate Audit or the OEC.
- Abbott Quality and Regulatory – If you have questions about the quality and safety of our products, contact your local Quality and Regulatory department.
- Global Environmental Health and Safety – Contact a Global Environmental Health and Safety representative if you have questions about a physical site and potential dangers.
- Global Purchasing Services – If you have questions about supplier relations, contact Global Purchasing Services.
Resources for Abbott Employees
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Learn More
- Learn more about our quality procedures.
- Learn more about the policies and procedures related to the Office of Ethics and Compliance.
- Learn more about our workplace harassment policy.
- Learn more about our environmental health and safety program.
- Learn more about our environmental program.
- Learn more about our social media policy.
- Learn more about our policy on electronic media use.
- Learn more about our policy on Insider Trading.
- Learn more about the privacy and data protection requirements for your location.
- Learn more about anti-bribery and anti-corruption laws from around the world.
- Learn more about our corporate policies.
Frequently Asked Questions
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Frequently Asked Questions
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