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Hill-Rom Global Code of Conduct

Hill-Rom Global Code of Conduct

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Q:<br />

Alan has recently taken<br />

over a number <strong>of</strong> supplier<br />

accounts and is eager to<br />

develop solid working relationships.<br />

One supplier has invited Alan and<br />

a few <strong>of</strong> his colleagues to attend a<br />

sporting event with representatives<br />

from the supplier. After receiving an<br />

<strong>of</strong>ficial invitation, Alan realizes that<br />

the supplier has invited him to sit in<br />

the supplier’s corporate box. Alan<br />

does not want to <strong>of</strong>fend the supplier<br />

but feels uncomfortable about the<br />

lavish nature <strong>of</strong> the corporate box.<br />

Should Alan just go along?<br />

A:<br />

No. While attending occasional<br />

events can be an excellent way<br />

to establish goodwill between<br />

our company and its business partners,<br />

such events must not be lavish in<br />

nature. Attending a sporting event in<br />

an exclusive corporate box could create<br />

— or appear to create — an obligation<br />

on <strong>Hill</strong>-<strong>Rom</strong>’s part. Alan should politely<br />

decline the invitation.<br />

<strong>Hill</strong>-<strong>Rom</strong> <strong>Global</strong> <strong>Code</strong> <strong>of</strong> <strong>Conduct</strong> 26<br />

Exchanging Business Courtesies<br />

We must make objective business decisions based on the merits<br />

and not because <strong>of</strong> inappropriate gifts or entertainment provided<br />

by third parties.<br />

Gifts<br />

We may never <strong>of</strong>fer or provide gifts to any customer, supplier,<br />

distributor, vendor or other person with whom we do business<br />

or seek to do business. As a common business courtesy, we may<br />

accept occasional gifts, such as a c<strong>of</strong>fee mug, as long as such<br />

gift is nominal in value, could not be perceived as lavish, and is<br />

not intended to improperly influence our business decisions.<br />

Meals and Other Hospitality<br />

We may accept occasional meals or hospitality from a customer,<br />

supplier, distributor, vendor or other person with whom we do<br />

business, as long as such meal or other hospitality is:<br />

• Modest in value and not lavish;<br />

• Provided in the course <strong>of</strong> a business relationship; and<br />

• Not likely to be perceived as an attempt to improperly<br />

influence a business decision.<br />

For specific details on whether to accept certain gifts and other<br />

business courtesies, please refer to our Policy on Exchanging<br />

Business Courtesies. If you have any concerns about a specific<br />

business courtesy, please seek guidance from your manager<br />

or the Compliance Office.<br />

November 2011<br />

Suppliers<br />

We select our suppliers based on price, quality, delivery, service,<br />

diversity, reputation, and business practices. We rely on our<br />

suppliers to provide quality products and services for our<br />

company and our customers. It is critical that our suppliers<br />

share our commitment to conducting business with integrity<br />

and in compliance with all applicable laws and regulations.<br />

When selecting or dealing with a supplier or potential supplier,<br />

we must:<br />

• Engage in fair and open competition;<br />

• Ensure suppliers are reputable and qualified;<br />

• Ensure the engagement <strong>of</strong> a supplier does not create<br />

an actual or apparent conflict <strong>of</strong> interest; and<br />

• Evaluate and approve suppliers before any materials,<br />

components, products or services are purchased from<br />

them in accordance with company policy.<br />

<strong>Hill</strong>-<strong>Rom</strong> <strong>Global</strong> <strong>Code</strong> <strong>of</strong> <strong>Conduct</strong> 27

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