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Hill-Rom Global Code of Conduct

Hill-Rom Global Code of Conduct

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Q:<br />

Deann was approached by Nick,<br />

an employee from an industry<br />

publication, who wants to<br />

include an article in an upcoming<br />

newsletter describing how a <strong>Hill</strong>-<strong>Rom</strong><br />

product was used by a customer to<br />

enhance productivity at an acute care<br />

facility. Deann provided information<br />

to Nick, and Nick sent her a draft <strong>of</strong><br />

the article to review. After reviewing<br />

it, Deann asked Nick to remove a<br />

statement attributed to her from the<br />

article. She then approved the other<br />

information provided in the article.<br />

Did Deann act properly?<br />

A:<br />

No. Even though the article did<br />

not contain a direct quote from a<br />

<strong>Hill</strong>-<strong>Rom</strong> employee, Deann should<br />

have worked with the V.P. <strong>of</strong> Corporate<br />

Communications to determine if it is<br />

appropriate for the company to provide<br />

information to the industry publication<br />

and, if so, what information would be<br />

appropriate to provide.<br />

<strong>Hill</strong>-<strong>Rom</strong> <strong>Global</strong> <strong>Code</strong> <strong>of</strong> <strong>Conduct</strong> 32<br />

Communications with Investors, Press,<br />

Interest Groups, and Through Social Media<br />

As a company, we must speak with one voice to investors, analysts,<br />

the press, and public interest groups and in accordance with all<br />

applicable laws and company policy. We must not communicate on<br />

behalf <strong>of</strong> <strong>Hill</strong>-<strong>Rom</strong> unless we are authorized to do so under our Public<br />

Disclosure Policy.<br />

Requests for Information<br />

If you receive a request for information about <strong>Hill</strong>-<strong>Rom</strong>, please keep in<br />

mind the following simple rules:<br />

• All requests from the media and public interest groups or for public<br />

endorsements or statements <strong>of</strong> support by the company should be<br />

referred to the V.P. <strong>of</strong> Corporate Communications; and<br />

• All investor analyst requests should be referred to the V.P. <strong>of</strong><br />

Investor Relations.<br />

Initiating Communications<br />

Similarly, we are prohibited from initiating communications on behalf<br />

<strong>of</strong> <strong>Hill</strong>-<strong>Rom</strong> with the press, investors or public interest groups unless<br />

we are authorized to do so under our Public Disclosure Policy.<br />

Social Media<br />

The internet provides unique opportunities to listen, learn and<br />

engage with internal and external stakeholders using a wide<br />

variety <strong>of</strong> tools like blogs, social networking sites, and chat rooms.<br />

However, we may not use social media tools to speak on behalf<br />

<strong>of</strong> <strong>Hill</strong>-<strong>Rom</strong>, conduct <strong>Hill</strong>-<strong>Rom</strong> business or otherwise respond<br />

to information requests for business purposes unless the use <strong>of</strong><br />

such tools is authorized by the Executive Leadership Team or<br />

its designee. Similarly, in our purely personal communications<br />

through social media, we may not share <strong>Hill</strong>-<strong>Rom</strong> confidential<br />

information or give the appearance that we are speaking on<br />

<strong>Hill</strong>-<strong>Rom</strong>’s behalf.<br />

November 2011<br />

<strong>Hill</strong>-<strong>Rom</strong> <strong>Global</strong> <strong>Code</strong> <strong>of</strong> <strong>Conduct</strong> 33

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