Bausch + Lomb Code of Business Conduct and Ethics

Competitive Intelligence
Gathering—RESPECTING THE
COMPETITION
Gathering accurate information about competitors,
suppliers, customers and the markets in which we
compete is vital to our business. However, when
gathering this information, we must always understand
and abide by Company policies and the law and never:
> misrepresent our identity or engage in disreputable
activities like listening in on private conversations or
looking through trash bins;
> induce or knowingly permit someone to breach their
confidentiality agreements;
> violate trade show rules to obtain competitor information;
> take others’ physical property without their permission;
> violate others’ intellectual property rights; or
> hire or permit someone else to gather competitive
intelligence on our behalf who does not first agree in
writing to do so in full accordance with these principles.
If a person interviewing for a job at Bausch + Lomb
tells me that they know important, confidential
details about a new product being developed by
a competitor, what should I do?
You should politely explain to the interviewee
that it would not be appropriate for them to tell
us any of our competitors’ trade secrets. We
consider candidates for employment based
on their experience and skills rather than any
specific information they might have about our
competitors’ confidential activities.
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