Hill-Rom Global Code of Conduct

Hill-Rom Global Code of Conduct 36
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.
Hill-Rom Global Code of Conduct 37