Hill-Rom Global Code of Conduct

November 2011 

Hill-Rom 

Global Code of Conduct 

Enhancing outcomes for 

patients and their caregivers.®

A Message from John Greisch A Message from Dan Dalton 

Dear Hill-Rom Colleagues, 

I am pleased to introduce you to the updated Hill-Rom Global Code of Conduct. 

Every day, around the world, we enhance outcomes for patients and their caregivers. This is our mission and our 

commitment to it defines who we are at Hill-Rom. It is also fundamental to our long-term success. 

Our mission is at the core of our Global Code of Conduct, which guides us as we navigate the complex world 

of health care. As you read the Code, you will also see references to Hill-Rom policies and procedures that provide 

practical advice as we operate our business in compliance with laws and regulations and adhere to the highest 

standards of business conduct. As the global health care marketplace presents ever-increasing challenges, our 

Hill-Rom Global Code of Conduct will help us enhance our brand and sustain our success well into the future. 

As a key part of our commitment to the Hill-Rom team, each of us must read the Hill-Rom Global Code of Conduct 

and agree to follow its guidance in all we do. I also ask that each Hill-Rom employee be vigilant in asking 

questions and voicing any concerns that may arise. 

We are privileged to work in a business that truly makes a difference. Our commitment to the Hill-Rom Global 

Code of Conduct is part of how we sustain that privilege. 

Thank you for all you do -- every day, around the world -- to enhance outcomes for patients and their caregivers. 

Sincerely, 

John Greisch 

Chief Executive Officer 

Hill-Rom Global Code of Conduct 2 November 2011 

Hill-Rom Fellow Employees, 

I’m pleased to join John in introducing you to our updated Hill-Rom Global Code of Conduct. 

At Hill-Rom, we understand that good compliance is simply good business. The business decisions we make 

on a daily basis not only impact our work at Hill-Rom, but also the lives of the patients, caregivers and other 

customers who use our products. It is important that the decisions we make gain their trust. We earn this trust 

by adhering to all relevant laws and regulations, living up to our values, abiding by our Global Code of Conduct, 

and being proactive in reporting problems. 

For all of us in the Compliance Office, our priority is to support you with clear guidance, education, and training 

as you navigate today’s increasingly competitive and complex global business environment. We recognize that 

understanding all of the rules and regulations that apply is not always easy so that is why we want to ensure that 

all Hill-Rom employees have access to information and resources that outline our company’s expectations in this 

area. In addition to updating our Global Code of Conduct, we’ve also recently enhanced our compliance program 

to enable easier access to compliance resources, user-friendly tools, and information. 

Our leadership in compliance will strengthen our reputation, sustain our long heritage of integrity, and ensure 

our continued success well into the future. 

Sincerely, 

Dan Dalton 

Vice President and Chief Compliance Officer 

Hill-Rom Global Code of Conduct 3

Introduction 

Our Core Values: 

• Respect 

• Responsiveness 

• Results 

• Integrity 

• Fun 

The Hill-Rom Global Code of Conduct applies our values to 

the day-to-day business situations we face. It demonstrates 

how our business conduct standards are applied through 

interactions with each of Hill-Rom’s key stakeholders: our 

customers and patients, our fellow employees, our company 

and investors, government regulators, and our communities 

and the public. 

Hill-Rom Global Code of Conduct 4 

November 2011 

Purpose 

Compliance with this Global Code and our policies and procedures is critical to our continued success in a 

highly complex and global health care industry. Our compliance and, in turn, our reputation is dependent 

upon the actions and decisions made by each of us every day. Observing our Global Code helps us maintain 

compliance with applicable laws and regulations in our highly regulated business, while inspiring the trust 

and confidence of our key stakeholders. 

Applicability 

This Global Code of Conduct and all relevant company policies and procedures apply to everyone who conducts 

business for Hill-Rom. This includes employees, officers and directors, agents, vendors, and consultants. Each 

of us is responsible for knowing and complying with the standards set forth in this Global Code and all relevant 

company policies and procedures. In addition, each of us is required to ask questions and voice concerns about 

compliance with our Global Code through appropriate channels to ensure that Hill-Rom’s standards are upheld. 

Violations of this Global Code or relevant policies and procedures may result in disciplinary action, up to and 

including termination. Failure to comply also may result in significant civil and criminal liability for individual 

employees and our company in addition to damage to our reputation. 

Expectations for Managers 

Managers have a responsibility to lead by example. They must set the highest standards of business conduct 

and demonstrate compliance with this Global Code every day. In addition, managers are expected to inspire 

compliance and personal accountability in others. If you are a manager, you must: 

• Ensure that your employees understand their responsibilities under the Global Code, company policy and 

procedures, and relevant laws and regulations; 

• Create an “open-door” environment where your direct reports and other employees feel comfortable asking 

questions, voicing concerns, or reporting perceived misconduct; 

• Include compliance as a factor when evaluating employees; and 

• Raise questions or concerns through the appropriate channels, including your manager and the Compliance Office. 

As a manager, you must also ensure employees, contractors, or others who make a good faith report are protected 

from any form of retaliation for doing so. Clearly communicate Hill-Rom’s “no retaliation” policy to your reports. 

Take appropriate action if you witness or suspect an act of retaliation, and report such conduct to the Compliance 

Office. For more information about Hill-Rom’s non-retaliation policy, please refer to page eight of this Global 

Code of Conduct. 


Our Key 

Stakeholders: 

• Patients 

and Customers 

• Fellow Employees 

• Company 

and Investors 

• Government 

Regulators 

• Communities 

and the Public 


Patients and Customers 

The patients who use our products, their caregivers, and our other customers 

are at the heart of our business. They depend upon us for the delivery of 

high quality, cost-effective products and services to meet their needs. We 

help meet their needs when we focus on meeting our standards for quality 

product design and manufacturing, accurate and truthful communications 

with our customers, appropriate interactions with health care providers, 

and safeguarding others’ private information. 

Fellow Employees 

At Hill-Rom, we are a community of individuals all working together to 

realize our company’s vision and mission. As a global organization, we 

value the diversity of our employees and recognize the unique ability of 

each individual to contribute to our success. To realize fully our individual 

and company potential, we must have a work environment of trust and 

respect for individuals. Our goal must be to foster an environment that is 

free of unlawful discrimination and harassment, and one that allows for 

open communication. 

Company and Investors 

We all have a responsibility to our company and our shareholders. As 

employees, we are responsible for ensuring that we act on our company’s 

behalf based on its interests rather than our own self-interests. We have 

a responsibility to ensure that our company’s books and records are 

accurate, that information we learn while performing our work is not 

used improperly, and that we treat company property and information 

with great care. Additionally, we have a responsibility to ensure that 

those with whom we do business share our commitment to follow 

our company’s standards for business integrity. 

Government Regulators 

The health care industry is dynamic, highly regulated and increasingly 

dependent on global governments as customers and payers. By 

complying with this Global Code and all relevant laws and regulations, 

we maintain our position as a trusted and reliable company with all 

government regulators and agencies that influence or participate in 

the markets for our products and services. 

Communities and the Public 

As a global health care company with thousands of employees, we 

also have a responsibility to the communities in which we live and 

operate and to the public at large. It is important that we act 

responsibly in all aspects of our local and national communities, 

including in the political, environmental, and charitable activities 

in which we participate. 

November 2011 


Our Global Code of Conduct cannot anticipate all of the situations 

we may face. It is designed to identify the major issues we may 

commonly confront and to provide clear guidance on those issues. 

It also provides clear direction so we can act quickly and with 

confidence that our actions are appropriate and consistent with 

our Global Code and our values. 

Each of us is responsible 

for knowing and following 

the policies and procedures 

that are relevant to our 

individual business 

activities. 


Compliance Resources 

In those situations not directly addressed by the Global Code, 

we have a number of other resources available to us. When 

seeking guidance, you should first consult this Global Code 

and any relevant policy or procedure. Our company maintains 

numerous policies and procedures that provide specific direction 

across many functions of our business. Each of us is responsible 

for knowing and following the policies and procedures that are 

relevant to our individual business activities. Many of the policies 

also are referenced in our Global Code and are available 

on our company intranet. 

If you still have questions about the proper course of action 

after reviewing the Global Code and any relevant policies or 

procedures, you should consult with your manager. In addition, 

you may consult subject matter experts within the organization. 

Non-Retaliation Policy 

Hill-Rom maintains a strict non-retaliation policy. Any employee, 

contractor or other person who raises a good faith concern 

or question about business practices or non-compliance with 

the Global Code or company policies and procedures will be 

protected from retaliation. A “good faith” report means that an 

individual has earnestly raised an issue that he or she believes 

may be in violation of this Global Code, company policies, and 

procedures or law. Acts of retaliation could include denial of 

benefits, termination, demotion, suspension, threats, harassment 

or discrimination. 

November 2011 

If you have questions about the proper course of action after 

reviewing the Global Code and any relevant policies and 

procedures, you should consult with your manager. In most 

cases, your manager is in the best position to address any 

questions or concerns. If you are not comfortable speaking with 

your manager, you can speak with another Hill-Rom manager. 

In addition, you may ask questions through a variety of other 

channels, including: 

Human Resources 

For employment or employee-related issues, such as questions or 

concerns about potential discrimination or harassment or concerns 

about management, please contact the Human Resources Department. 

Legal Department 

For questions about laws and regulations that may apply to our 

business, please contact the Legal Department. There are lawyers 

assigned to support each business within the company, as well as 

subject matter experts that can assist you. 

Finance Department 

For questions regarding finance or accounting issues, please 

contact the Finance Department. 

Compliance Office 

The Compliance Office is available to assist you with any questions 

or concerns regarding our Global Code or company policies and 

procedures. In addition, for those situations where you are more 

comfortable asking questions or raising concerns with someone 

other than your manager or a subject matter expert, you may 

discuss your questions or concerns with the Compliance Office. 

If requested, your identity will be kept strictly confidential to 

the extent permitted by applicable law. Please keep in mind, 

however, that maintaining your confidentiality may limit Hill- 

Rom’s ability to investigate your concerns. 

Compliance Helpline 

You may also make a report through our Compliance 

Helpline, which is managed by an independent third party. 

The Compliance Helpline is accessible 24 hours a day, seven 

days a week, with translators available when necessary. 

Where allowed by local law, you may choose to make an 

anonymous report through the Compliance Helpline. 


Compliance Contacts 

Compliance Office 

complianceoffice@hill-rom.com 

Compliance Helpline 

The Compliance Helpline is a tool through which we may report concerns of real or potential misconduct. It is available 

24 hours a day, seven days a week, with translators on staff, if necessary. Where allowed by local law, you may choose to 

make an anonymous report. All information received through the Compliance Helpline will be kept confidential to the 

extent possible and permitted by law. 

You may use either of the following two methods to submit a report to the Compliance Helpline: 

• File a report online by logging onto (http://www.hill-rom.EthicsPoint.com) 

• Call the Compliance Helpline at the following numbers: 

U.S. 1-866-433-8442 

Australia 1-800-339276 

Austria 0800-291870 

Belgium 0800-77004 

Canada 1-866-433-8442 (English) or 1-855-350-9393 (French) 

China (Northern) 10-800-712-1239 

China (Southern) 10-800-120-1239 

Czech Republic 800-142-550 

France 0800-902500 

Germany 0800-1016582 

Hong Kong 800-964214 

India 000-800-100-1071 

Italy 800-786907 

Ireland 1-800-61-5403 

Japan 00531-121520 (Japanese) or 0044-22-11-2505 (English) 

Lebanon 01-426-801 

Mexico 001-8008407907 (Spanish) or 001-866-737-6850 (English) 

Netherlands 0800-0226174 

Norway 800-15654 

Poland 0-0800-121-15-71 

Portugal 800-8-12-499 

Russia 8-10-8002-6053011 

United Arab Emirates 8000-021 

Singapore 800-1204201 

Spain 900-991498 

Sweden 020-79-8729 

Switzerland 0800-562907 

Turkey 0811-288-0001 

United Kingdom 08-000328483 

These numbers are subject to change. If a local number is not working, please log onto http://www.hill-rom.EthicsPoint.com to file a report. 


November 2011 


Table of Contents 


I. CUSTOMERS & PATIENTS 14 

Creating High Quality, Innovative Products 15 

Accurate and Truthful Communications 15 

Interactions with Health Care Providers 16 

Government Contracting and Tenders 17 

Data Privacy 18 

II. FELLOW EMPLOYEES 20 

Employment Practices 21 

Workplace Safety and Health 22 

Employee Privacy 23 

III. COMPANY & INVESTORS 24 

Avoiding Conflicts of Interest 25 

Exchanging Business Courtesies 26 

Suppliers 27 

Maintaining Accurate Books and Records 28 

Insider Trading 29 

Protecting Company Information and Property 30 

Business Intelligence 31 

Communications with Investors, Press, 

Interest Groups, and Through Social Media 32 

IV. REGULATORS 34 

Health Care Laws and Regulations 35 

Bribery and Corruption Laws 36 

World Trade Controls and Boycotts 38 

Complying with Worldwide Competition Laws 39 

Government Audits, Inquiries and Investigations 40 

V. COMMUNITIES & THE PUBLIC 42 

Protecting the Environment 43 

Political Activities and Contributions 44 

Community Involvement 44 

VI. DISCLOSURE OF WAIVERS 46 

VII. CERTIFICATION 47 

November 2011 Hill-Rom Global Code of Conduct 13

I. Customers & Patients 

Every interaction we have with health care providers, 

patients, payers, and other customers is an opportunity 

to demonstrate our commitment to enhancing patient 

and caregiver outcomes. For more than 80 years, we 

have nurtured our longstanding relationships with a 

broad range of customers. Thousands of hospitals and 

other health care providers depend on Hill-Rom to 

help them deliver safe, efficient, and effective health 

care. We must work to build and maintain the trust 

and positive relationships we have established with 

our customers. 


November 2011 

Creating High Quality, Innovative Products 

We all must work to provide products that are safe and effective 

for their intended uses. We must: 

• Design, validate, test, and evaluate our products to meet current 

industry standards and maximize patient safety and outcomes; 

• Manufacture and service our products in compliance with our 

standard operating procedures and never cut corners; 

• Meet all regulatory requirements concerning product safety 

and labeling; 

• Ensure that our suppliers meet our supplier requirements; and 

• Raise quality and safety issues immediately. 

Reporting Potential Product Problems 

We also must be vigilant for problems with our products in the field. 

We may learn of quality or safety issues relating to our products in 

many different ways — through conversations with customers or 

suppliers, telephone calls, emails, blogs, chat rooms, letters, faxes, 

and even in conversations with neighbors. No matter the source, 

we must report this information promptly. 

When you receive information from any source that our products 

may not be functioning properly or that they may be unsafe, you 

must report that information within 24 hours to the Technical 

Services Hotline for your local country. 

Accurate and Truthful Communications 

We market and sell our products solely based on their 

efficacy, quality, safety, and price. All information provided 

to our customers and patients about our products and 

services, including availability and delivery of our products, 

must be truthful, balanced, and supported by data and 

relevant experience. All materials that are created for 

use in marketing and selling our products must be 

reviewed and approved by Regulatory Affairs and the 

Legal Department. 

Q: 

Rose is preparing a shipment 

of stretchers for delivery 

when she notices that several 

side rails are not latching correctly. 

The latch mechanism seems to be 

made out of a different material than 

what she’s seen before. She knows 

that patient safety is a big concern, 

but she is also aware that this order 

is late and the customer is unhappy 

that it has not yet been delivered. 

Should she speak up? 

A: 

Yes. Rose should report 

the situation immediately 

to her manager, another 

member of management and/or the 

Quality Control Department. Meeting 

a delivery schedule is never an excuse 

for allowing a product that may not 

be working correctly to be shipped 

to a customer. This could put patients 

at risk and damage the reputation 

of our company and our customers. 


Q: 

Angela has been working 

with a big hospital account 

for months to sell it a Hill-Rom 

mattress. She has proposed that the 

hospital try a few mattresses out for a 

couple of weeks to see if the account 

likes them. Angela follows Hill-Rom’s 

evaluation procedure and sets up a 

30-day evaluation of four surfaces for 

the account. After 30 days, the hospital 

is not ready to make a decision. Angela 

decides to continue the evaluation. 

This cycle continues for more than six 

months with the account avoiding a 

decision about purchasing the product 

while Angela continues to extend the 

evaluation period. Has Angela 

acted appropriately? 

A: 

No. Allowing hospitals a brief 

evaluation period to evaluate 

a product is an appropriate 

practice. However, the evaluation 

generally should have ended after 

the initial 30 days. Hill-Rom policies 

must be followed for any extensions, 

and it generally will not be appropriate 

to extend an evaluation beyond 90 

days. Failing to remove an evaluation 

product in a timely manner violates 

company policy. Additionally, use of a 

Hill-Rom product at no cost beyond the 

evaluation period may be viewed as 

providing an improper incentive to the 

facility, which could result in criminal 

or civil penalties being levied against 

our company. 


Interactions with Health Care Providers 

We are prohibited from offering anything of value to an existing or 

potential customer in order to improperly influence the selection of 

our products. Improper incentives may include but are not limited 

to inappropriate meals, entertainment, trips, gifts, free product or 

services, honoraria, grants or scholarships. On occasion, we may 

provide approved educational items, meals or other items of value 

in accordance with company policies and procedures. 

Hill-Rom has established a Policy on Interactions with Health Care 

Providers. Our sales and marketing teams must understand and 

follow this policy and any corresponding procedures when 

interacting with health care providers. 

Complying with these rules is vital to our stakeholders and our 

ultimate goal of enhancing outcomes for our patients and their 

caregivers. Consequences for failing to comply with Hill-Rom 

policies and legal requirements can result in substantial criminal 

or civil fines, and possibly even personal criminal liability. 

Additionally, failure to comply with these rules can directly 

affect our reputation in the marketplace, our brand, and our 

success. If you are ever uncertain whether a meal or other 

activity is appropriate, please contact your manager or the 


November 2011 

Government Contracting and Tenders 

When we respond to government tenders and contract 

directly with government agencies, we must comply with 

a complex set of rules and work closely with the Legal 

Department. Failure to follow these rules can result in the 

loss of contracts and significant and even criminal liability. 

At a minimum, we must ensure that: 

• All representations to the government in project proposals, 

bids, and reports are complete, accurate, and not misleading; 

• All claims for payment reflect work accurately and do not 

overstate the amount to which Hill-Rom is entitled; 

• We cooperate in good faith with all government requests for 

audits and inspections; and 

• We immediately report any suspected violations of laws or 

regulations, company policies or our contractual obligations 

to the Legal Department. 

For U.S.-based employees, please consult the Fraud, Waste, 

and Abuse Policy and the Policy on Selling to the Government for 

additional guidance on responding to government tenders 

or contracting with the government. For employees located 

outside of the U.S., please consult the Legal Department for 

additional information on government contracting. 


Q: 

Bianca works in Hill-Rom’s 

Accounts Receivable 

Department. Bianca’s job 

sometimes requires her to mail 

invoices and other documentation 

containing patient information. Bianca 

mailed an invoice containing patient 

information to the wrong patient by 

accident. What should she do? 

A: 

Bianca should notify her 

manager and the Hill-Rom 

Privacy Officer immediately. 

Hill-Rom may have legal obligations to 

notify the patient that his or her 

information was accidentally provided 

to another patient. Bianca should 

ensure that she provides all relevant 

information, such as the date the 

error occurred and when she became 

aware the information was accidentally 

disclosed, to the Privacy Officer. 

The Hill-Rom Privacy Officer 

can be reached by telephone 

at 812-931-2246, or via email 

at privacy_officer@hill-rom.com 


Data Privacy 

We must appropriately safeguard the privacy of all personal information 

concerning patients, customers, suppliers, contractors, vendors, and 

others that we receive in the course of our work. 

Patient Information 

We must adequately safeguard the privacy of medical records and 

other patient information that we receive or access while performing 

our jobs. As a medical device and technology company, we are 

subject to various health information privacy laws, and we must 

understand and fully comply with them. 

What is Patient Information? 

Patient information is any information about health status, 

the provision of health care, or payment for health care that 

can be linked to a specific individual. It includes any information 

related to a patient’s health condition, services received, 

invoices, medical charts, and insurance coverage information. 

Violations of health information privacy laws can result in criminal 

or civil liability and/or fines. If you need further information about 

health information privacy laws, please contact the Hill-Rom 

Privacy Officer or the Legal Department. 

Customer and Supplier Information 

We must also protect confidential information belonging to our 

customers, suppliers, contractors, and vendors. Confidential 

information may include business records or data, personal 

and financial information, personal identification numbers, 

bank records, trade secrets, and proprietary information. 

If you have access to or otherwise come into contact with this 

type of information, you must ensure that it is handled according 

to our Policy on Confidential Information and Non-Disclosure 

Agreements, as well as any confidentiality obligations we have 

in agreements with third parties. For more information, please 

contact the Privacy Officer or the Legal Department. 

November 2011 


II. Fellow Employees 

As a global company, we live and work in many different 

countries. No matter where we do business, we all work 

together to develop and deliver superior products to 

customers and patients around the world. There are 

thousands of us working together to achieve this. We 

may come from a wide range of cultures and we may 

have different perspectives, but our diversity is a 

fundamental strength. 


November 2011 

Employment Practices 

Anti-Discrimination 

We hire and promote our employees based solely on job-related 

qualifications. We do not make employment decisions on the basis 

of race, color, gender, age, national origin, religion, sexual orientation, 

gender identity and expression, marital status, citizenship, disability, 

veteran status or any other legally protected factor, in accordance 

with local laws. 

Anti-Harassment 

Our workplace must be an environment that is safe and inspiring, 

where each of us can work free from harassment. Harassment may 

be physical, verbal or visual. Examples of harassing behavior include 

unwelcome sexual advances or remarks, offensive jokes, and 

disparaging comments. No matter the form, it is never appropriate. 

What is Harassment? 

Harassment is behavior that creates an offensive, intimidating, 

humiliating or hostile work environment that unreasonably 

interferes with another person’s work. 

Compliance with Local Labor and Wage Laws 

We aim to be a positive social presence in every community where 

we work. We promote basic human rights by following applicable 

local labor laws and we do not allow child or forced labor by our 

company, vendors or suppliers. We also follow all applicable wage 

and hour laws, including minimum wage, overtime, and maximum 

hour rules. 

If you have any questions or concerns regarding our employment 

practices, please contact your manager, your human resources 

representative or the Legal Department. 

Q: 

Lately, Ruth’s manager 

has been making her feel 

uncomfortable. He often 

engages her in conversations about 

his personal life, including some 

recent problems in his marriage. 

Their discussions make Ruth feel 

uneasy and she would prefer that 

they stick to professional dialogue. 

She has expressed this to her 

manager, but he continues to corner 

her at her desk and in the hallways 

to talk about his issues. What should 

she do to fix this situation? 

A: 

While the Global Code 

is not meant to prohibit 

employees from sharing 

personal experiences with one 

another, one of its core purposes 

is to ensure that all employees are 

treated with dignity and respect. 

Because Ruth has made it clear to 

her manager that these discussions 

are unwelcome and are making her 

feel uncomfortable, her manager’s 

behavior may violate Hill-Rom’s Global 

Code and harassment policies. She 

should report his conduct right away 

to her human resources representative 

— and remember that the company 

prohibits any retaliation against those 

who report suspected harassment in 

good faith. 



Workplace Safety and Health 

We are committed to providing a safe and healthy working 

environment. We each have a responsibility to understand and 

follow all company safety and security policies and procedures 

as well as applicable laws and regulations. Nothing justifies working 

around or ignoring any safety rule — whether a company policy, 

regulation or law. If you become aware of or suspect any safety 

issues or unsafe working conditions, you should report the situation 

to your manager, your site safety leader or the Legal 

Department immediately. 

Violence and Weapons in the Workplace 

Physical intimidation, threats of violence and physical abuse have 

no place at Hill-Rom. Neither do weapons of any sort. We all have 

an obligation to create a safe and respectful workplace. If you know 

of or suspect incidents or threats of workplace violence, report your 

concerns immediately. If you believe there is an emergency or that 

someone is in imminent danger, please contact your site safety 

leader and/or local authorities. 

Substance Abuse 

We may not be on company property, in company vehicles or perform 

company work if we are impaired by drugs or alcohol. On rare 

occasions, we may be permitted to consume alcohol at designated 

work functions. These include holiday parties or office-wide 

celebrations. Moderation should be exercised during all such 

events. You should consult with your human resources 

representative to learn more about the drug and alcohol 

policies applicable to your location. 

November 2011 

Employee Privacy 

We must ensure that personal information about current, former or 

prospective employees is protected at all times. In general, we must 

collect, use and share personal information only with those who 

have a legitimate need to use it and who will protect it in accordance 

with Hill-Rom’s policies. Where appropriate, we should provide 

notice to explain how Hill-Rom will use an employee’s personal 

information and respect individual choices regarding the collection, 

use and disclosure of personal information. We should retain or 

destroy personal information in accordance with company policy. 

What is Personal Information? 

Personal information is any information that can be used, alone 

or in combination with other information, to identify a specific 

individual. It includes such information as a person’s name, 

address, email address, date of birth, driver’s license number, 

financial account numbers, Social Security number or other 

government identification number and other identifiers. 

If you believe personal information about Hill-Rom employees has 

been disclosed or used inappropriately, please contact the Privacy 

Officer or the Legal Department immediately. Failure to do so could 

subject our company to fines and/or regulatory action. 

The Hill-Rom Privacy Officer 

can be reached by telephone 

at 812-931-2246, or via email 

at privacy_officer@hill-rom.com 


III. Company and Investors 

Our continued success depends on maintaining 

financial performance. We strive to provide 

honest, accurate, and timely information to 

our shareholders about our performance and 

to make clear disclosures in all public reports 

and communications. 


November 2011 

Avoiding Conflicts of Interest 

We must act solely in the best interest of our company and 

shareholders at all times. This means we must never allow 

personal or family interests to influence our professional judgment. 

In addition, you must identify and work with management to 

resolve any potential conflict between your personal interests 

and those of the company. 

What is a Conflict of Interest? 

A conflict of interest arises when our personal relationships, 

activities, associations or financial interests interfere, or even 

appear to interfere, with our independent judgment or obligation 

to act in the best interest of our company. 

While there are many situations that may create a potential 

conflict of interest, the most common types of conflicts that we 

may face include: 

• Having a substantial financial or professional interest in a supplier, 

vendor, customer, competitor, distributor or other company with 

which we seek to do business; 

• Turning Hill-Rom’s business opportunities into our own, such 

as through side businesses; 

• Operating or working with a business that competes with or 

contracts with Hill-Rom; 

• Making personnel decisions regarding family members, friends 

or those with whom we have romantic relationships; 

• Engaging our company in a business relationship with a family 

member or a business in which a family member holds a significant 

financial interest; and 

• Participating in outside business activities that compete with 

our company or that affect our ability to devote appropriate 

time and attention to our assigned job responsibilities. 

Each of us must identify potential conflicts or the appearance 

of a conflict when they arise and bring them to the attention of 

our manager. If you are considering any activity that might create 

an appearance of a conflict, you must receive written approval 

in advance from your manager. If you are a manager and need 

additional guidance on a potential conflict, please contact your 

human resources representative or the Compliance Office. 

Q: 

Julian manages a number of 

Hill-Rom supplier relationships. 

His sister owns a company 

that is seeking to do business with 

ours. Julian’s department is currently 

reviewing proposals from potential 

new suppliers, and he tells his sister to 

submit one for her company. Without 

disclosing his personal relationship, 

Julian makes the case to the rest of the 

team that his sister’s business is the 

superior candidate. Her company is 

then awarded the contract. Did Julian 

do anything wrong? 

A: 

Yes. By awarding his sister’s 

company our business without 

disclosing his relationship, Julian 

has created a conflict of interest. For 

Hill-Rom to consider his sister’s company 

as a potential supplier, Julian must disclose 

his sister’s relationship to the company that 

is seeking to do business with us. He 

must also not participate in, or seek to 

influence, any part of the procurement 

process. This ensures that Hill-Rom retains 

the best possible business partners that 

are chosen without personal bias. It also 

ensures that our suppliers each get a 

fair chance at competing for our business. 


Q: 

Alan has recently taken 

over a number of supplier 

accounts and is eager to 

develop solid working relationships. 

One supplier has invited Alan and 

a few of his colleagues to attend a 

sporting event with representatives 

from the supplier. After receiving an 

official invitation, Alan realizes that 

the supplier has invited him to sit in 

the supplier’s corporate box. Alan 

does not want to offend the supplier 

but feels uncomfortable about the 

lavish nature of the corporate box. 

Should Alan just go along? 

A: 

No. While attending occasional 

events can be an excellent way 

to establish goodwill between 

our company and its business partners, 

such events must not be lavish in 

nature. Attending a sporting event in 

an exclusive corporate box could create 

— or appear to create — an obligation 

on Hill-Rom’s part. Alan should politely 

decline the invitation. 


Exchanging Business Courtesies 

We must make objective business decisions based on the merits 

and not because of inappropriate gifts or entertainment provided 

by third parties. 

Gifts 

We may never offer or provide gifts to any customer, supplier, 

distributor, vendor or other person with whom we do business 

or seek to do business. As a common business courtesy, we may 

accept occasional gifts, such as a coffee mug, as long as such 

gift is nominal in value, could not be perceived as lavish, and is 

not intended to improperly influence our business decisions. 

Meals and Other Hospitality 

We may accept occasional meals or hospitality from a customer, 

supplier, distributor, vendor or other person with whom we do 

business, as long as such meal or other hospitality is: 

• Modest in value and not lavish; 

• Provided in the course of a business relationship; and 

• Not likely to be perceived as an attempt to improperly 

influence a business decision. 

For specific details on whether to accept certain gifts and other 

business courtesies, please refer to our Policy on Exchanging 

Business Courtesies. If you have any concerns about a specific 

business courtesy, please seek guidance from your manager 

or the Compliance Office. 

November 2011 

Suppliers 

We select our suppliers based on price, quality, delivery, service, 

diversity, reputation, and business practices. We rely on our 

suppliers to provide quality products and services for our 

company and our customers. It is critical that our suppliers 

share our commitment to conducting business with integrity 

and in compliance with all applicable laws and regulations. 

When selecting or dealing with a supplier or potential supplier, 

we must: 

• Engage in fair and open competition; 

• Ensure suppliers are reputable and qualified; 

• Ensure the engagement of a supplier does not create 

an actual or apparent conflict of interest; and 

• Evaluate and approve suppliers before any materials, 

components, products or services are purchased from 

them in accordance with company policy. 


Q: 

Marissa, a Hill-Rom Regional 

Director, and her sales team 

have exceeded their revenue 

goal for the quarter. Marissa plans to 

record the revenue that is above her 

area’s goals in the next quarter. This 

way, they’ll reach their goal for the 

next quarter, too. Can she do this? 

No. Marissa and her area must 

A: recognize all revenue in the 

period that it is earned. This is 

necessary to comply with acceptable 

accounting principles. In addition to 

satisfying applicable laws and standards, 

we must be sure to maintain accurate 

books and records so we can make 

informed business decisions for the 

benefit of our stakeholders and 

our company. 


Maintaining Accurate Books and Records 

All of our stakeholders — and in particular our investors, auditors and 

regulators — depend on us to keep records of our business on which 

we and they can rely. We must record and report information so that it 

reflects an accurate and complete picture of our business transactions. 

We must never knowingly create or participate in creating incomplete 

or misleading information or inaccurately record the timing of any event 

or transaction. Each of us is responsible for the accuracy of the records 

we create and maintain. 

Manufacturing 

We must keep our manufacturing and quality inspection records 

accurately and completely to facilitate inspection, audit review, 

and regulatory reporting. 

Sales and Distribution 

We must keep accurate written records of our product sales 

and distribution so that we can generate accurate financial 

reports and projections. 

Financial Information 

It is critical that we prepare and maintain accurate financial records. 

We must make full, fair, accurate, timely, and understandable 

disclosure in reports that our company files with our financial 

regulators and in other public communications made by our 

company. We must do this in accordance with the Generally 

Accepted Accounting Principles and other applicable auditing 

and regulatory guidance. 

Should you become aware that any company books and records 

are inaccurate or misleading, you must immediately raise the 

issue with your manager. Inaccurate financial records must 

immediately be reported to the Finance Department or the 

Compliance Office. 

November 2011 

Insider Trading 

We are strictly prohibited from buying or selling Hill-Rom 

securities (like stock, options, and bonds), or the securities 

of other companies, on the basis of “material inside information” 

that we learn of in a variety of ways, including by way of our 

work with Hill-Rom. We also are prohibited from sharing this 

information with others outside our company so that they can 

buy or sell Hill-Rom or other securities with the benefit of 

material inside information. Directors, officers, and other 

designated “insiders” may face even further restrictions. 

What is “Material Inside Information?” 

In general, this is information that has not been made public 

and that a reasonable investor would find important when 

deciding whether to buy, sell or hold a corporation’s securities. 

Information is considered public only if it has been made 

generally available to investors, such as in our company’s filings 

with the U.S. Securities and Exchange Commission or in a press 

release, and if investors have been allowed a reasonable period 

to react to the information (normally within two trading days). 

Some examples of material inside information could include: 

• Non-public financial results, such as monthly or quarterly 

revenue, net income or earnings per share; 

• Mergers, acquisitions, and important business developments; 

• Important regulatory or litigation developments; and 

• Development or release of significant new products or recall of 

existing products. 

Violation of insider trading laws is a serious crime and can result in 

significant civil and criminal penalties. We must follow our Insider 

Trading Policy and consult with the Legal Department to resolve 

any questions we may have before we trade in Hill-Rom securities. 


Q: 

Andrew works in Hill-Rom’s 

Marketing Department. While 

attending a trade show, Andrew’s 

laptop was stolen. Andrew knows that 

his laptop contains confidential business 

information. What should Andrew do? 

A: 

Andrew should notify his 

manager and the IT Service 

Desk immediately. He should be 

sure to inform the Service Desk of all 

confidential information that may have 

been stored on his laptop. 


Protecting Company Information and Property 

Intellectual Property and Confidential Information 

We must not disclose our company’s intellectual property or confidential 

business information with anyone inside or outside the company unless 

they have a legitimate business need to know it and we have obtained 

prior authorization from management. Each of us is responsible for 

knowing what information we deal with is confidential and following 

all policies to protect it. The improper disclosure of intellectual 

property or confidential business information can adversely affect 

our financial stability and our company’s competitive position. 

What is Intellectual Property? 

Intellectual property includes patents, trade secrets, trademarks, 

copyrights, design rights, trade dress, logos, know how, photos/ 

videos, individuals’ names and likenesses, and other intangible 

industrial or commercial property. 

We must ensure that our conversations are not overheard, sensitive 

documents are secure, and that our mobile devices such as computers 

and phones are not left unattended or lost. Our obligation to maintain 

the confidentiality of our company’s intellectual property and 

confidential business information continues even after we leave 

employment at Hill-Rom. 

What is Confidential Business Information? 

Confidential business information is company information 

that is not public. It includes new product designs or 

development plans, financial data and projections, business 

development plans, strategic plans, customer lists, sales and 

marketing data, pricing, customer and supplier contracts, 

and access passwords. 

For more guidance on your obligations to Hill-Rom’s intellectual 

property and confidential business information please consult the 

Intellectual Property Policy, the Policy on Confidential Information 

and Non-Disclosure Agreements or the Legal Department. 

Physical Property 

We must take care to prevent the theft, destruction or misuse 

of Hill-Rom’s physical property, including company funds, 

equipment, communications systems, and facilities. We 

must use company property for business purposes only, 

except for the incidental personal use of communication 

systems, and never for our own personal gain or that of 

another person. 

November 2011 

Business Intelligence 

We respect the confidential and proprietary information of our 

competitors and our customers. Therefore, we may use only lawful 

and ethical methods to gather information about our competitors 

and customers. We may collect business intelligence from public 

sources, such as company websites, published articles, advertisements, 

public presentations, and customers who are under no confidentiality 

obligation. We also must communicate to our agents, consultants 

or other business partners who gather information on our behalf that 

they must observe guidelines similar to Hill-Rom’s when acting on 

our behalf. 

We must not: 

• Seek to obtain sensitive information directly from any competitor; 

• Lie or make misrepresentations when gathering information, 

or use covert means of gathering information; or 

• Recruit employees with the intent to obtain any confidential 

information. 

Upon inadvertent receipt of confidential information about a 

competitor or customer, immediately call the Legal Department 

without passing it to others so that the appropriate action may 

be taken to address the situation. 

Q: 

Alberto recently hired Vicki, 

who previously worked in the 

Marketing Department of one 

of Hill-Rom’s competitors. Alberto wants 

to ask Vicki about our competitor’s 

marketing plans for a product under 

development by the competitor. 

Should Alberto ask Vicki about 

this information? 

A: 

No. It would be improper for 

Alberto to ask Vicki, or Vicki 

to volunteer, to provide 

confidential or proprietary information 

about her former employer. 


Q: 

Deann was approached by Nick, 

an employee from an industry 

publication, who wants to 

include an article in an upcoming 

newsletter describing how a Hill-Rom 

product was used by a customer to 

enhance productivity at an acute care 

facility. Deann provided information 

to Nick, and Nick sent her a draft of 

the article to review. After reviewing 

it, Deann asked Nick to remove a 

statement attributed to her from the 

article. She then approved the other 

information provided in the article. 

Did Deann act properly? 

A: 

No. Even though the article did 

not contain a direct quote from a 

Hill-Rom employee, Deann should 

have worked with the V.P. of Corporate 

Communications to determine if it is 

appropriate for the company to provide 

information to the industry publication 

and, if so, what information would be 

appropriate to provide. 


Communications with Investors, Press, 

Interest Groups, and Through Social Media 

As a company, we must speak with one voice to investors, analysts, 

the press, and public interest groups and in accordance with all 

applicable laws and company policy. We must not communicate on 

behalf of Hill-Rom unless we are authorized to do so under our Public 

Disclosure Policy. 

Requests for Information 

If you receive a request for information about Hill-Rom, please keep in 

mind the following simple rules: 

• All requests from the media and public interest groups or for public 

endorsements or statements of support by the company should be 

referred to the V.P. of Corporate Communications; and 

• All investor analyst requests should be referred to the V.P. of 

Investor Relations. 

Initiating Communications 

Similarly, we are prohibited from initiating communications on behalf 

of Hill-Rom with the press, investors or public interest groups unless 

we are authorized to do so under our Public Disclosure Policy. 

Social Media 

The internet provides unique opportunities to listen, learn and 

engage with internal and external stakeholders using a wide 

variety of tools like blogs, social networking sites, and chat rooms. 

However, we may not use social media tools to speak on behalf 

of Hill-Rom, conduct Hill-Rom business or otherwise respond 

to information requests for business purposes unless the use of 

such tools is authorized by the Executive Leadership Team or 

its designee. Similarly, in our purely personal communications 

through social media, we may not share Hill-Rom confidential 

information or give the appearance that we are speaking on 

Hill-Rom’s behalf. 

November 2011 


IV. Regulators 

As a medical device and technology company, many 

laws and regulations affect how our company conducts 

its business. These laws and regulations are designed 

to protect patients and the quality of health care 

they receive. For our company to succeed, each 

and every one of us must understand the laws and 

regulations that relate to our work. This means that 

each of us must be informed, knowledgeable, and 

committed to following the laws and regulations 

that apply to our job responsibilities. 


Health Care Laws and Regulations 

In the development, production, promotion, sale and distribution of 

our products, we strictly follow all U.S. and foreign health care laws 

and regulations. We must understand and fully comply with these 

requirements as well as Hill-Rom’s health care policies and procedures. 

We also are expected to report any suspected violations of any 

applicable U.S. federal health care program requirement, as well 

as other violations of Hill-Rom’s policies and procedures, to the 

Compliance Office immediately. 

Medical Device Laws 

We must comply with all applicable laws, regulations, and company 

requirements in the design, testing, production, promotion, 

registration, approval, and distribution of our products. These laws 

vary from country to country and we must take care to ensure 

that we understand and comply with the country laws where we 

do business. In addition, our communications with government 

agencies that regulate medical devices — like the U.S. Food and 

Drug Administration and similar regulatory authorities in other 

countries — must be complete, accurate, and not misleading. 

Promotion and Sales 

We will sell our products based on their efficacy, quality, safety and 

price, not on the basis of inappropriate financial relationships, gifts, 

inappropriate meals or entertainment with customers, health care 

providers or patients. In addition, we must promote and market 

our products for authorized uses only and using only those materials 

that have been approved in accordance with company policy. 

For more information, please refer to the sections on Accurate 

and Truthful Information and Interactions with Health Care Providers 

on pages 15 and 16 of this Global Code. 

Reimbursement and Billing 

We must ensure that reimbursement activity with public and 

private payers is always legitimate and allowed by applicable 

rules governing the relationship. We must also ensure that any 

claims we prepare and submit to public or private payers are 

accurate and consistent with all applicable requirements. If you 

are involved in the billing and collection function, you are expected 

to understand and comply with all billing policies and procedures 

as well as applicable requirements of third-party payers. Hill-Rom 

only bills for goods or services that are properly ordered and 

delivered or performed. 

Disclosure of Status as Ineligible Person 

Resources 

For further information on our 

company’s policies for complying 

with medical device laws, sales 

and promotion practices, and 

reimbursement and billing, 

please refer to: 

• The Quality Manual 

• Policy on Interactions with 

Health Care Providers 

• Third Party Payer Compliance 

Manual 

• Fraud, Waste, and Abuse Policy 

We should also regularly consult 

Quality Assurance and Regulatory 

Affairs, the Third Party Payer 

Compliance Program, the Hill-Rom 

Legal Department, the Compliance 

Office or other subject matter experts 

when we have questions about whether 

our conduct is in compliance with 

applicable law. If you believe that Hill- 

Rom has violated a health care law or 

regulation, please report your concern 

to the Compliance Office immediately. 

November 2011 

Our company does not hire or work with individuals who have 

committed fraud or other unlawful actions against U.S. government 

health care programs. Individuals who have engaged in such 

activities will have been notified that their names appear on one 

of the exclusion lists maintained by the U.S. government. If you or 

someone you work with is on one of these exclusion lists, you 

must immediately notify the Compliance Office. 



Bribery and Corruption Laws 

We receive government approval to manufacture, import and export, 

transport, and sell our products because we meet government 

requirements, not because we bribe or otherwise inappropriately 

influence regulators. Similarly, we receive commercial contracts 

with government and private customers because we offer high quality 

products and services, not because we “pay off” our customers. 

And we do not engage or permit others, like agents and distributors, 

to do what we cannot. 

All countries in which we do business have laws prohibiting companies 

and individuals from paying bribes or engaging in corrupt activities to 

influence business decisions. We comply with these laws, and we will 

not tolerate attempts to improperly influence business decisions to 

secure favorable treatment for our company. 

As a company subject to U.S. laws, Hill-Rom is prohibited from offering 

or paying anything of value to a government official in exchange for 

gaining an improper business advantage. In many countries, significant 

parts of the health care system are operated or funded by the 

government, and virtually all health care professionals — 

including hospital administrators, doctors, nurses and hospital 

purchasing managers — may be employees of public institutions 

and may be considered government officials. 

Bribery of Government Officials 

We must never offer, give or pay anything of value to a government 

official to win or retain business or to improperly influence official 

decision making. A “government official” can include federal, state 

or local government employees, political candidates and even 

employees of government-owned businesses, such as doctors 

at state-run hospitals. It may not always be obvious that you 

are working with a government official, so you should consult 

with your manager or the Compliance Office if you have 

any questions. 

Commercial Bribery 

Company employees and others working on our behalf also 

are prohibited from participating in any form of commercial 

bribery. We must never make any business decisions based 

on any personal benefit given or offered to us. Likewise, we 

may never offer a bribe to, or receive a kickback from, our 

customers, suppliers, patients, other commercial partners 

or anyone else working on their behalf. 

November 2011 

Engaging Third Parties 

We may never hire third parties, such as distributors, agents, 

lobbyists, and consultants, to make a bribe or enter into an 

arrangement where we believe the third party may be making 

illegal payments. We must screen appropriately any third parties 

who perform work on our behalf. If you suspect that a third party 

associated with our company is making illegal payments, notify 

your manager or the Compliance Office immediately. 

The consequences for violating anti-corruption laws can be serious. 

The payment of illegal bribes can subject both our company and 

individuals engaging in the illegal conduct to significant criminal 

and civil fines and possibly even imprisonment. In addition, bribing 

a government official or other individual in one country may result 

in criminal or civil liability not only in that country but also in a 

different country. 

Please check with your manager, the Legal Department or the 

Compliance Office to determine whether a payment to a government 

official or other individual is appropriate. If deemed appropriate, 

the payment must be properly recorded and accounted for so that 

Hill-Rom may comply with all applicable laws. 

For further guidance, please see our Global Anti-Corruption Policy, 

or consult with your manager or the Compliance Office. 

Q: 

Stefan would like to engage 

a consultant to assist in 

registering a new Hill-Rom 

bed with the Ministry of Health. Stefan 

knows that it typically takes several 

months to complete registration with 

the government agency before a 

device is allowed on the market in 

his country. However, a consultant that 

Stefan is considering hiring told Stefan 

he can obtain approval in two weeks. 

Stefan really wants to register this 

new bed quickly—should he hire 

the consultant? 

A: 

Stefan must go through the 

review and due diligence 

process specified in the 

Global Anti-Corruption Policy before 

hiring a consultant. The consultant’s 

promise to register the product within 

a very short time period raises red flags 

that the consultant could be making 

illegal payments to shorten the 

registration time. Stefan should seek 

guidance from the Legal Department 

or the Compliance Office before 

proceeding. Offering or paying a bribe 

through a third party is a serious matter 

and can result in disciplinary action, 

up to and including termination. 


Q: 

Kyle is traveling to meet with a 

potential customer in Germany. 

Part of the purpose for his trip 

is to present the design for a new medical 

device on which Hill-Rom is planning 

to begin production. Kyle is bringing 

his laptop, which contains the product 

design, as well as a variety of sales and 

marketing brochures. What does Kyle 

need to know about export law? 

A: 

Kyle should be aware that any 

technology he has with him 

when he travels internationally 

may be considered an export. Export 

controls apply to most products, 

software or technology, as well as 

samples, laptops, schematics and 

product manuals. Kyle must ensure 

that any such items remain in his sole 

control and possession for the duration 

of the trip. He should also make sure 

that hand-carrying these items to his 

particular destination is permissible 

under U.S. export control laws, and 

he has obtained all required licenses. 

His trip to Germany may not present 

significant issues, but if he is sent to 

another country next month, he must 

check the regulations again for that 

destination. At any time, if he has any 

questions about hand-carried items, he 

should contact the Legal Department. 


World Trade Controls and Boycotts 

We must follow the complicated rules that govern the export of our 

products and technology from one country to another and the rules 

that govern who we can do business with. In general, when we ship or 

transfer our products and technology from one country to another, or 

enter into business relationships with other entities, those of us 

responsible for international operations must work closely with the 

Legal Department to understand and apply our policies and 

procedures regarding trade controls. There are three general types 

of trade issues that arise: 

Sanctions 

The United States and other countries impose partial and total 

restrictions on trade with particular nations, entities and individuals 

without an appropriate license. We must ensure that Hill-Rom is not 

prohibited from shipping products or technology to countries, or 

prohibited from doing business with entities and persons, for which 

we need a license. 

Export Controls 

The U.S. and other countries restrict the export of particular 

technology and information without an appropriate license, 

regardless of the destination. We must ensure that when we 

export products and technology from one country to another, 

we do not need a license or that we have the appropriate license. 

Boycotts 

Some countries require vendors to boycott doing business 

with a particular country, company or person. Certain boycott 

requests must be reported to the U.S. government. Because 

anti-boycott laws are complex, all boycott requests must be 

reported to the Legal Department immediately. 

If you have any questions or need guidance about trade control 

policies, please contact the Legal Department. 

November 2011 

Complying with Worldwide Competition Laws 

We achieve results based on the quality of our products and our 

employees, never through unfair business practices. We must abide 

by all competition laws (sometimes referred to as “antitrust” laws) 

that apply to our work. These laws may vary from market to market, 

but their goal is the same. They are designed to preserve free and 

open competition and promote a competitive marketplace. Failure 

to comply with these laws can have serious and far-reaching 

consequences for our company and the individuals involved. 

Sharing Information 

We must not share commercial or market information with our 

competitors concerning pricing, conditions and terms of sale, 

costs, markets or customers. 

Collusion with Competitors 

We must not discuss or agree with competitors to set prices, allocate 

markets or tenders, discriminate against customers or suppliers or 

coordinate activity in any other way. 

Restricting Customers and Suppliers 

We must consult with and obtain approval from the Legal Department 

when we are considering entering into an agreement with 

a customer that would prohibit a customer from purchasing 

products from our competitors. Similarly, we also must consult 

with and obtain approval from the Legal Department when we are 

considering entering into an agreement with a supplier that could 

place restrictions on supplying one of our competitors. 

For additional guidance, please refer to our Antitrust Policy, 

which is located on our intranet, or the Legal Department. Should 

any competitor, customer or supplier begin to discuss any issues 

that raise antitrust concerns with you, please contact the Legal 

Department immediately. 

RULES FOR DEALING WITH COMPETITORS 

ALWAYS: 

• Refuse to take part in discussions or arrangements 

that may be seen as anti-competitive; 

• Communicate any actual or potential anti- 

competitive discussions you have witnessed 

or taken part in to the Legal Department or 

the Compliance Office; 

• Seek advice from the Legal Department if 

you come across confidential or proprietary 

information about Hill-Rom’s competitors. 

NEVER: 

Q: 

A: 

• Share confidential information with competitors 

— including bids, proposals or strategies; 

• Discuss pricing, whether formally or informally, 

with competitors; 

• Agree, whether formally or informally, 

to allocate markets or territories. 

Carla has a good friend who 

works for one of Hill-Rom’s 

competitors. The two meet 

for lunch, and Carla reveals that 

Hill-Rom plans to submit a bid for 

capital equipment to a local hospital. 

Her friend indicates that he is 

struggling in his own job and asks 

if she would consider not entering 

the bid, allowing his company a better 

chance at securing the business 

instead. Carla wants to help her 

friend, but knows that what he’s 

asking of her isn’t right. What should 

Carla do? 

Carla should refuse to speak 

about this subject with her 

friend and should relay the 

conversation to the Legal Department 

or the Compliance Office immediately. 

We must never discuss dividing 

clients, contractors or vendors with 

a competitor. It is illegal to make any 

agreement, even an informal oral 

agreement, with a competitor that 

restricts competition. In addition, 

we must never share confidential 

information with our competitors. 

This includes bids, proposals or 

strategies. When making her report, 

Carla should be sure to mention her 

disclosure of Hill-Rom’s plans to submit 

the bid for capital equipment, so that 

Hill-Rom can take appropriate action. 



Government Audits, Inquiries and Investigations 

We must handle all contacts with the government professionally and 

seriously. As with anyone else, we must be truthful and not misleading. 

For all non-routine requests or inquiries from government regulators, 

we must work with the Legal Department. 

Government Audits and Inspections 

We must handle all audits and inspections in accordance with our 

Government Audits, Inquiries and Investigations Policy or other 

applicable procedure. We must respond truthfully and completely 

to all questions and we make documents and people available upon 

request. Please consult with the Legal Department or the Quality 

Assurance and Regulatory Affairs Department, as appropriate. 

Non-Routine Inquiries 

In our highly regulated business, we may receive routine and non-routine 

communications from the government. All routine communications 

with the government and regulatory inspections should be handled 

consistent with departmental policies and procedures. Non-routine 

inquiries, such as document requests, subpoenas, court orders and 

requests for information from any Congressional committee, should 

be immediately directed to the Legal Department for appropriate 

handling pursuant to the Government Audits, Inquiries and 

Investigations Policy. 

Search Warrant Execution 

In the unlikely event law enforcement attempts to execute a 

search warrant, immediately contact your manager or your 

site leader and the Legal Department. You should obtain the 

name and phone number of the agent in charge and a copy of 

the warrant and other relevant paperwork. You should also 

remain polite, professional, and cooperative. Please keep 

track of the items and documents the agents seize and provide 

such information to the Legal Department pursuant to the 

Government Audits, Inquiries and Investigations Policy. 

Interview Requests 

Should a government agent attempt to speak with you 

about Hill-Rom business, it is preferred, but not required, 

that you contact the Legal Department before you speak with 

them so Hill-Rom has the opportunity to protect confidential 

business information and assert legal privileges. However, 

you are entitled to speak with the agent first or refuse to 

speak with the agent if you choose to do so. In any event, 

contact the Legal Department as soon as possible about 

any such contact. 

November 2011 


V. Communities & the Public 

At Hill-Rom, we understand that the ongoing vitality 

of the communities where we do business has a direct 

impact on the long-term health of our business 

Therefore, we are committed to participating actively 

in our communities. We strive to improve the global 

communities where we conduct business, not only 

through the high quality products and services we 

provide, but also through the contributions we make. 

In every community where we conduct business, we 

will support our communities, protect our environment, 

and conduct political activity responsibly. 


Protecting the Environment 

At Hill-Rom, we strive to meet or exceed all applicable environmental 

laws, regulations, and permit conditions. We also use environmentally 

sound manufacturing practices to ensure protection of the 

surrounding environment. Environmental regulations may include 

rules governing the use, control, transportation, storage and disposal 

of regulated materials that may reach the environment as a part 

of wastewater, air emissions, solid waste, hazardous waste or 

uncontained spills. Even non-regulated materials must be managed 

in a responsible, and sustainable manner. Many of these materials 

can also have adverse environmental impacts if mishandled. 

We are expected to understand and comply with health, safety, and 

environmental regulations in our daily activities. If your job involves 

contact with any regulated materials or requires that you make 

decisions about how any materials are used, stored, transported 

or disposed of, you need to understand how they should be legally, 

responsibly and safely handled. 

Please refer to our Environmental Policy or our Health & Safety 

Policy for further guidance. If you have additional questions, please 

contact the Director of Environmental Health and Safety or the 


November 2011 Hill-Rom Global Code of Conduct 43


Political Activities and Contributions 

When appropriate and legal, our company may choose to engage 

in political discussions about issues that affect our business and may 

make political contributions. We may not engage in political activities 

and discussions on behalf of Hill-Rom unless such activities are 

authorized by the V.P. of Government Affairs. We may make contributions 

to governmental elections only where such contributions are lawful 

and in accordance with our Policy on Political Contributions. 

Our company recognizes and encourages our individual right to 

participate in the communities where we live and work. However, 

we may only participate in political activities on our own time and 

at our own expense. We may never use or even appear to use 

Hill-Rom’s name, time, funds, facilities, assets or other resources, 

directly or indirectly, for political purposes or contributions without 

express written approval from the V.P. of Government Affairs. 

Political Action Committee 

Our company has organized the Hill-Rom Holdings, Inc. Political 

Action Committee (HRPAC). This committee solicits voluntary 

contributions from company employees to support candidates 

for U.S. federal government, as permitted by law. For additional 

information regarding the HRPAC, please contact the V.P. of 

Government Affairs. 

Community Involvement 

Our mission carries a commitment to the communities where we 

work and live. Acknowledging social responsibility through active 

citizenship and thoughtful giving is part of our unwavering 

commitment to our communities. 

November 2011 


VI. Disclosure Of Waivers 

Any waiver of any provision of this Global Code must 

be approved in advance by the Hill-Rom Board of 

Directors or an appropriate committee of the Board 

of Directors. Any waiver of the Global Code approved 

by the Board of Directors for an executive officer or 

director must be promptly disclosed to shareholders. 


November 2011 

VII. Certification 

I have received and reviewed my copy of the Hill-Rom Global Code of Conduct. I 

understand that complying with the Global Code of Conduct and all relevant 

policies is a condition of my continued employment with Hill-Rom. I am aware 

that Hill-Rom expects the highest degree of integrity from me in all of the work 

that I perform. I recognize that it is impossible for Hill-Rom to list every possible 

action that may violate this Global Code of Conduct, and that Hill-Rom reserves 

the right to take disciplinary measures, up to and including termination, when 

addressing violations. 

I have read the Global Code of Conduct thoroughly, and I agree to comply with 

the standards it sets forth. I understand that the Global Code of Conduct may 

be updated as needed, and that I have a responsibility to read and comply with 

the most current provisions. 

I am not aware of any current violation of the Global Code of Conduct that I have 

not reported to my manager or other appropriate resource. 

In addition, I understand that this Global Code of Conduct is not a contract 

of employment, subject to applicable local law. Nothing in the Global Code of 

Conduct is intended to alter Hill-Rom’s policy of at-will employment or any 

at-will employment agreement. 


Hill-Rom Corporate Offices 

1069 State Route 46 East 

Batesville, IN 47006 USA 

812.934.7777 

Enhancing outcomes for 

patients and their caregivers.®

Hill-Rom Global Code of Conduct

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