Ethics & Compliance
Policies, Codes and Disclosures
All employees, including part-time employees, are required to complete Global Code of Conduct training annually. Anti-Bribery and Anti-Corruption are also annual training requirements.
Global Code of Conduct
Our Global Code of Conduct and other relevant policies and procedures apply to everyone who conducts business for Hillrom and its operating companies.
Global Anti-Corruption Policy
Hillrom operates in strict compliance with all applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act ("FCPA"). Our Global Anti-Corruption Policy applies to all of Hillrom, including all subsidiaries, and its operating companies’ suppliers, distributors and other partners globally.
The Global Third-Party Code of Conduct
The Code sets forth Hillrom’s requirements for distributors, suppliers, business partners and other third parties registering, promoting, selling, or supplying Hillrom products or otherwise interacting with government officials or health care providers on our behalf (“Third Parties”). Third parties are responsible for adhering to Hillrom’s Global Third-Party Code of Conduct. Download Hillrom Global Third Party Code of Conduct.
Interaction with Health Care Providers
Hillrom has a global policy on Interactions with Health Care Providers, which provides specific guidance to our employees on acceptable practices for marketing to, and interacting with, health care providers. Hillrom 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.
Conflict Minerals Policy
Hillrom has filed a Conflict Minerals Report, which is publicly available at hillrom.com. Download report.
California Health & Safety Code
Click the following link to view information on our efforts to comply with the California Health & Safety Code.
California Transparency in Supply Chain Disclosure
Click the following link to view information on our efforts to comply with the California Transparency in Supply Chain Disclosure.
Employees are expected to voice their concerns or file a report if they in good faith believe that a violation of law, regulation, other legal obligation, or policy or procedure may occur, is occurring, 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, the individual should immediately report such potential retaliation to the Compliance Office or the Compliance Helpline. All such reports will be investigated.
All employees and any other stakeholders are encouraged to raise a compliance concern or ask a question through one of the following channels:
- Manager - In most cases, a direct manager is in the best position to address any questions or concerns.
- Human Resources - For employment or employee-related issues, such as questions or concerns about potential discrimination or harassment or concerns about management, please contact the Human Resources Department.
- Legal Department - For questions about laws and regulations related to Hillrom’s business, contact the Legal Department.
- Finance Department - For questions regarding finance or accounting issues, contact the Finance Department.
- Global Compliance Office - Questions or concerns can be sent directly to the Global Compliance Office through the following email address: GlobalComplianceOffice@hillrom.com.
- Compliance Helpline - The Compliance Helpline is a tool through which individuals may report concerns of real or potential misconduct. It is available 24 hours a day, seven days a week, with translators on staff, if necessary. Where allowed by local law, reports can be made anonymously. All information received through the Compliance Helpline will be kept confidential to the extent possible and permitted by law.
There are two methods to submit a report to the Compliance Helpline:
- File a report online by logging onto http://www.hillrom.EthicsPoint.com
- Call the toll-free Compliance Helpline: (866) 433-8442 (available in multiple languages)
Answering compliance questions and concerns is a top priority, and we take these inquiries very seriously. The company will promptly investigate the matter and, where appropriate, take disciplinary action and implement measures to correct and prevent similar conduct.
The Hillrom whistleblower helpline and policy are communicated to employees on a regular basis, multiple times a year, using several platforms including, but not limited to the following:
- Helpline posters visible in all physical locations
- Communications from senior management
- Online training(s)
- Live training sessions
- Annual Compliance Week
Global Compliance Program
Hillrom has created and implemented a comprehensive global compliance program designed to help maintain the highest professional and ethical standards. The Hillrom Chief Compliance Officer, who is 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 employees, including part-time employees, are required to complete annual Global Code of Conduct and Anti-Corruption Policy training.
The Hillrom Global Compliance Office, supported by Internal Audit, Legal and HR, performs reviews and audits across our 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 the regions and countries, including the US, to be reviewed.
Additionally, the Global Compliance Office performs integrity due diligence on third parties that work on Hillrom’s behalf, and that are expected to interact with non-U.S. government officials or healthcare providers. Hillrom automatically re-checks third parties against worldwide databases, publicly exposed persons, sanctions and embargo lists on a monthly basis. On an annual basis, our strategic distributors are required to take Hillrom’s Distributor Compliance training and to re-certify to Good Business Practices.
We have a Global Compliance Committee that meets quarterly, comprised of senior officers of the company (including the CEO), as well as Regional Compliance Committees. The Global Compliance Office provides regular reports to the Audit Committee of the Board of Directors. The Audit Committee has specific responsibility for compliance program oversight. 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.