Ethics & Compliance
Abbott’s approximately 90,000 employees understand that earning trust is a result of their actions, the decisions they make and the manner in which they do business every day – in matters large and small. As they perform every aspect of their business activities, our employees must be guided by a clear understanding of legal and regulatory requirements, company policies and procedures, our Promise and our Values.
Effective Compliance Program
Ethical conduct and compliance with the law are central to fulfilling our responsibility to our stakeholders. Honesty, fairness and integrity represent the necessary conditions of an ethical workplace and are nonnegotiable. Our approach to ethics and compliance is multifaceted and covers seven key areas:
1. Leadership: The Chief Ethics and Compliance Officer (CECO) is responsible for the management and operation of the Office of Ethics and Compliance (OEC) and the development and enhancement of the compliance program. The CECO makes regular reports regarding compliance matters to the Chairman of the Board and Chief Executive Officer, senior level leadership and Abbott’s Board of Directors and Committees. The Business Conduct Committee (BCC) consists of senior level leadership and is chaired by the CECO. The BCC is accountable directly to the Chairman of the Board and the Chief Executive Officer and was established to assist in the implementation of the Compliance Program. The BCC holds periodic meetings to discuss matters including: 1. the legal and regulatory environment, risk areas and best practices; and 2. modifications to the compliance program on the basis of such evaluation. OEC staff provides dedicated support to each of Abbott’s businesses.
2. Written Standards:
Code of Business Conduct
Our basic guidelines and requirements for ethical behavior are set forth in The Abbott Code of Business Conduct, published in print and online in 35 languages. Abbott employees read, understand and certify adherence to our Code annually. Our Code states clearly that Abbott does not tolerate illegal or unethical behavior in any aspect of our business. It emphasizes the importance of ethical and honest conduct, adhering to Abbott’s policies and procedures, treating confidential information appropriately, avoiding conflicts of interest and maintaining Abbott’s books and records with accuracy and integrity. Further, it requires our employees to ask questions or report any concerns.
Policies and Procedures
In addition to our Code, we adopt policies and procedures that guide employees as they conduct their day-to-day activities. They encompass relevant laws and regulations, including food and drug laws and laws relating to government health care programs. They also take into account industry best practices, including provisions of the International Federation of Pharmaceutical Manufacturers & Associations (IFPMA) Code of Pharmaceutical Marketing Practices, the updated Pharmaceutical Research and Manufacturers of America (PhRMA) Code on Interactions with Healthcare Professionals and the updated Advanced Medical Technology Association (AdvaMed) Code of Ethics on Interactions with Health Care Professionals, as well as other applicable industry codes. We encourage and expect our suppliers and other business partners to adhere to applicable industry codes as well. We regularly update our policies to incorporate changes to the law and industry codes, including rules regarding gifts, meals and education we provide to health care professionals.
3. Effective Lines of Communication: Creating an environment where employees can raise questions and concerns helps us advance our commitment to ethical behavior. We have established systems and processes for employees to ask questions and report suspected or actual violations of our Code, policies and procedures. We offer a number of resources to employees, such as our Ethics and Compliance Helpline, a telephone and Web-based hotline available 24 hours a day, seven days a week. Employees also may contact the OEC or the CECO directly.
In 2009, we received approximately 1,000 inquiries and allegations. All allegations are analyzed and corrective actions are taken where necessary, including terminating employees or supplier relationships. When appropriate, we report information about breaches of our Code to senior management.
The OEC also creates opportunities to engage in face-to-face interactions with employees by participating in national and regional sales meetings and local site meetings. Issues also are highlighted on our OEC intranet site and through other targeted communications vehicles.
4. Training: Training and education programs for employees increase their awareness of our Code’s precepts and the legal and ethical implications of their actions and behaviors. Abbott’s compliance program provides training and education programs in a variety of content areas, using various methods of adult learning.
For example, employees in the U.S., Puerto Rico and Latin America participate in our Legal and Ethics Resource Network program, a Web-based training system designed to increase awareness of the legal and ethical implications of business decisions.
Another successful approach has been the use of interactive ethics challenge activities in conjunction with internal meetings. These face-to-face interactions allow for informal discussions with OEC personnel and provide opportunities to learn more about the company's policies and the importance of individual actions.
One such program, "Score with Ethics," is an interactive question and answer assessment based on the core values of our company. It was developed to help international employees learn more about our Code and the resources available to assist them. This learning tool was made available to our Affiliates worldwide to test and enhance their ethics and compliance knowledge.
5. Accountability: Abbott employees are expected to adhere to our Code as a condition of their continued employment. Any Abbott employee who violates our Code, or any policy or procedure, is subject to appropriate disciplinary action. Any Abbott employee who fails to report a violation of Abbott policy or procedure of which he/she is, or should have been, aware may be subject to the same disciplinary action. Abbott does not tolerate retaliation against anyone who makes a good-faith report regarding a violation or potential violation of our Code, policies or procedures. These guidelines are well publicized and enforced.
6. Assessment: The OEC may utilize results from internal investigations, internal audits and internal monitoring programs to assess the effectiveness of and identify areas for improvement in the compliance program and relevant business practices. In addition, we consider the external environment, including government investigations, settlements, industry codes and government guidance to identify new opportunities to enhance the compliance program.
7. Remediation: Results of investigations, audits and monitoring are communicated to the appropriate OEC staff and business leaders. When an area for improvement is identified, the OEC partners with the business to implement corrective actions.
Transparency
A growing number of laws in the United States require greater transparency in the relationships between our industry and individuals and entities involved in providing health care. These laws impose various combinations of code of conduct restrictions on activities involving health care professionals and health care organizations and tracking and reporting of payments and benefits provided. Abbott complies with all such laws, which currently exist in California, the District of Columbia, Maine, Massachusetts, Minnesota, Nevada, Vermont and West Virginia.
Operating Globally, Acting Locally – International Affiliate Compliance Program
Understanding and adhering to local laws, regulations and other requirements is vital for our employees no matter where they work. The Affiliate Compliance Program has been designed to formalize compliance programs, including distinct policies and procedures in each of the countries where Abbott operates to ensure compliance with local requirements.
The Affiliate Compliance Program is managed by local Affiliate Compliance Committees, which are composed of the general manager and other top executives, representing all of Abbott's businesses within a country. The Affiliate Compliance Committees are responsible for the day-to-day function of the compliance program, including monitoring of compliance, providing awareness and training of the program, revising policies and procedures and providing guidance to local employees. The committees also meet on a regular basis to discuss emerging issues and work with the International Ethics and Compliance organization as new programs initiated by the OEC are rolled out. Compliance professionals are located throughout the world and provide oversight and guidance to the Affiliate Compliance Committees.
Abbott’s approximately 90,000 employees understand that earning trust is a result of their actions, the decisions they make and the manner in which they do business every day – in matters large and small. As they perform every aspect of their business activities, our employees must be guided by a clear understanding of legal and regulatory requirements, company policies and procedures, our Promise and our Values.
Effective Compliance Program
Ethical conduct and compliance with the law are central to fulfilling our responsibility to our stakeholders. Honesty, fairness and integrity represent the necessary conditions of an ethical workplace and are nonnegotiable. Our approach to ethics and compliance is multifaceted and covers seven key areas:
1. Leadership: The Chief Ethics and Compliance Officer (CECO) is responsible for the management and operation of the Office of Ethics and Compliance (OEC) and the development and enhancement of the compliance program. The CECO makes regular reports regarding compliance matters to the Chairman of the Board and Chief Executive Officer, senior level leadership and Abbott’s Board of Directors and Committees. The Business Conduct Committee (BCC) consists of senior level leadership and is chaired by the CECO. The BCC is accountable directly to the Chairman of the Board and the Chief Executive Officer and was established to assist in the implementation of the Compliance Program. The BCC holds periodic meetings to discuss matters including: 1. the legal and regulatory environment, risk areas and best practices; and 2. modifications to the compliance program on the basis of such evaluation. OEC staff provides dedicated support to each of Abbott’s businesses.
2. Written Standards:
Code of Business Conduct
Our basic guidelines and requirements for ethical behavior are set forth in The Abbott Code of Business Conduct, published in print and online in 35 languages. Abbott employees read, understand and certify adherence to our Code annually. Our Code states clearly that Abbott does not tolerate illegal or unethical behavior in any aspect of our business. It emphasizes the importance of ethical and honest conduct, adhering to Abbott’s policies and procedures, treating confidential information appropriately, avoiding conflicts of interest and maintaining Abbott’s books and records with accuracy and integrity. Further, it requires our employees to ask questions or report any concerns.
Policies and Procedures
In addition to our Code, we adopt policies and procedures that guide employees as they conduct their day-to-day activities. They encompass relevant laws and regulations, including food and drug laws and laws relating to government health care programs. They also take into account industry best practices, including provisions of the International Federation of Pharmaceutical Manufacturers & Associations (IFPMA) Code of Pharmaceutical Marketing Practices, the updated Pharmaceutical Research and Manufacturers of America (PhRMA) Code on Interactions with Healthcare Professionals and the updated Advanced Medical Technology Association (AdvaMed) Code of Ethics on Interactions with Health Care Professionals, as well as other applicable industry codes. We encourage and expect our suppliers and other business partners to adhere to applicable industry codes as well. We regularly update our policies to incorporate changes to the law and industry codes, including rules regarding gifts, meals and education we provide to health care professionals.
3. Effective Lines of Communication: Creating an environment where employees can raise questions and concerns helps us advance our commitment to ethical behavior. We have established systems and processes for employees to ask questions and report suspected or actual violations of our Code, policies and procedures. We offer a number of resources to employees, such as our Ethics and Compliance Helpline, a telephone and Web-based hotline available 24 hours a day, seven days a week. Employees also may contact the OEC or the CECO directly.
In 2009, we received approximately 1,000 inquiries and allegations. All allegations are analyzed and corrective actions are taken where necessary, including terminating employees or supplier relationships. When appropriate, we report information about breaches of our Code to senior management.
The OEC also creates opportunities to engage in face-to-face interactions with employees by participating in national and regional sales meetings and local site meetings. Issues also are highlighted on our OEC intranet site and through other targeted communications vehicles.
4. Training: Training and education programs for employees increase their awareness of our Code’s precepts and the legal and ethical implications of their actions and behaviors. Abbott’s compliance program provides training and education programs in a variety of content areas, using various methods of adult learning.
For example, employees in the U.S., Puerto Rico and Latin America participate in our Legal and Ethics Resource Network program, a Web-based training system designed to increase awareness of the legal and ethical implications of business decisions.
Another successful approach has been the use of interactive ethics challenge activities in conjunction with internal meetings. These face-to-face interactions allow for informal discussions with OEC personnel and provide opportunities to learn more about the company's policies and the importance of individual actions.
One such program, "Score with Ethics," is an interactive question and answer assessment based on the core values of our company. It was developed to help international employees learn more about our Code and the resources available to assist them. This learning tool was made available to our Affiliates worldwide to test and enhance their ethics and compliance knowledge.
5. Accountability: Abbott employees are expected to adhere to our Code as a condition of their continued employment. Any Abbott employee who violates our Code, or any policy or procedure, is subject to appropriate disciplinary action. Any Abbott employee who fails to report a violation of Abbott policy or procedure of which he/she is, or should have been, aware may be subject to the same disciplinary action. Abbott does not tolerate retaliation against anyone who makes a good-faith report regarding a violation or potential violation of our Code, policies or procedures. These guidelines are well publicized and enforced.
6. Assessment: The OEC may utilize results from internal investigations, internal audits and internal monitoring programs to assess the effectiveness of and identify areas for improvement in the compliance program and relevant business practices. In addition, we consider the external environment, including government investigations, settlements, industry codes and government guidance to identify new opportunities to enhance the compliance program.
7. Remediation: Results of investigations, audits and monitoring are communicated to the appropriate OEC staff and business leaders. When an area for improvement is identified, the OEC partners with the business to implement corrective actions.
Transparency
A growing number of laws in the United States require greater transparency in the relationships between our industry and individuals and entities involved in providing health care. These laws impose various combinations of code of conduct restrictions on activities involving health care professionals and health care organizations and tracking and reporting of payments and benefits provided. Abbott complies with all such laws, which currently exist in California, the District of Columbia, Maine, Massachusetts, Minnesota, Nevada, Vermont and West Virginia.
Operating Globally, Acting Locally – International Affiliate Compliance Program
Understanding and adhering to local laws, regulations and other requirements is vital for our employees no matter where they work. The Affiliate Compliance Program has been designed to formalize compliance programs, including distinct policies and procedures in each of the countries where Abbott operates to ensure compliance with local requirements.
The Affiliate Compliance Program is managed by local Affiliate Compliance Committees, which are composed of the general manager and other top executives, representing all of Abbott's businesses within a country. The Affiliate Compliance Committees are responsible for the day-to-day function of the compliance program, including monitoring of compliance, providing awareness and training of the program, revising policies and procedures and providing guidance to local employees. The committees also meet on a regular basis to discuss emerging issues and work with the International Ethics and Compliance organization as new programs initiated by the OEC are rolled out. Compliance professionals are located throughout the world and provide oversight and guidance to the Affiliate Compliance Committees.