Hill-Rom Global Code of Conduct
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