Hill-Rom Global Code of Conduct

Hill-Rom Global Code of Conduct 40
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
Hill-Rom Global Code of Conduct 41