All Hillrom associates, part and full-time, are required to complete Global Code of Conduct and Anti-Corruption training requirements every year:
This code—and other relevant policies and procedures—applies to everyone employed by Hillrom and its global family of companies. Download Hillrom's Global Code of Conduct.
Hillrom operates in strict compliance with all applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act ("FCPA"). Our own Global Anti-Corruption Policy also applies to every Hillrom associate and those of our subsidiaries, suppliers, distributors and other global partners. Download Hillrom Global Anti-Corruption Policy.
This details our requirements for third party distributors, suppliers, business partners and parties that register, promote, sell, or supply Hillrom products, or otherwise interact with government officials or health care providers on our behalf. Download Hillrom Global Third Party Code of Conduct.
This global policy provides specific guidance for associates on acceptable practices for marketing to, and interacting with, health care providers. Hillrom’s policy is consistent with the provisions of the AdvaMed Code of Ethics on Interactions with Health Care Professionals, published by the Advanced Medical Technology Association and Medtech Canada Code of Conduct on Interactions with Healthcare Professionals and Government Officials, published by Medtech Canada.
Hillrom has filed a Conflict Minerals Report with the United States Securities and Exchange Commission which is publicly available at hillrom.com. Download report.
We encourage and expect employees to voice their concerns or file a report if they believe in good faith that a violation of law, regulation, other legal obligation, or policy or procedure is occurring, may occur, or has occurred; or if they are concerned about any other reportable matter defined above. Any employee, worker, contractor or other person who raises a good faith concern or question about business practices or non-compliance with any law, regulation, or company policy and procedure shall be protected from retaliation.
Hillrom employees who engage in retaliation or intimidation in violation of company policy shall be subject to disciplinary action, up to and including termination. If any individual believes that he or she has been retaliated against for reporting or participating in an investigation, they should immediately report such potential retaliation to the Compliance Office or the Compliance Helpline for investigation.
Employees and any other stakeholders are encouraged to raise a compliance concern or ask a question through one of the following channels:
Answering your compliance questions and concerns is a top priority and we take these inquiries very seriously. We will promptly investigate the matter and, where appropriate, take disciplinary action and put measures in force to correct and prevent similar conduct.
The Hillrom whistleblower helpline and policy are communicated to employees on a regular basis all year through several platforms including, but not limited to, the following:
We’ve created and implement a comprehensive global compliance program designed to help maintain the highest professional and ethical standards. The Hillrom Chief Compliance Officer, a member of our Executive Leadership Team (ELT), and the Global Compliance Office provide employees with clear guidance, education and training so they can appropriately navigate today's increasingly complex health care environment. All full- and part-time employees are required to complete annual Global Code of Conduct and Anti-Corruption Policy training.
Our Global Compliance Office—supported by Internal Audit, Legal and HR—reviews and audits the entire Hillrom organization to assess compliance with our Code of Conduct, Anti-Corruption Policy and other relevant policies. Proactive compliance assessments and audits are conducted regularly using a risk-based approach to determine all regions and countries that need to be reviewed.
Additionally, the Global Compliance Office performs integrity assessments on third parties that work on Hillrom’s behalf and are expected to interact with non-U.S. government officials or healthcare providers. Hillrom automatically re-checks third parties against worldwide databases and publicly exposed persons, sanctions and embargo lists on a monthly basis. Our strategic distributors are required to take Hillrom’s Distributor Compliance training annually and to re-certify to Good Business Practices.
Our Global Compliance Committee meets quarterly and is comprised of senior officers of the company (including the CEO), as well as Regional Compliance Committees. The Global Compliance Office has specific responsibility for compliance program oversight and provides regular reports to the Audit Committee of the Board of Directors. In turn, the Chief Compliance Officer attends ELT meetings where corporate strategy and direction are determined.
Hillrom does not undertake any animal testing, outsource any animal testing to any third party, conduct any clinical trials, or outsource clinical trials to any third party.