Earning trust and behaving ethically and with integrity is one of our core values. This is the right thing to do and protects our reputation.
We have an extensive compliance programme with priorities set through a risk assessment process, further details are available in our Annual Report. We are also an active participant in many of the local medical device trade associations of the countries in which we operate and we played an instrumental role in drafting the Code of Ethical Business Practice for our European industry association, MedTech Europe.
Our legal and compliance function works with the Audit and Risk Committee and the Board. Further details are available here. This approach provides visibility to our leadership regarding compliance initiatives and ensures positive “tone at the top” with respect to adherence to the Company’s ethical principles.
We have developed a Code of Ethics and Business Conduct, and a series of Global Policies which cover a range of business conduct and compliance issues, focusing particularly on bribery and corruption risks. We strive to ensure that all relevant employees complete the necessary training, and completion is carefully monitored (in 2016, over 3,000 of relevant employees completed the Code of Ethics training).
We have introduced a third party-managed whistle-blowing solution to enable employees and third parties to both seek advice and guidance on ethical issues, and also to report suspected breaches of our Code of Ethics and Business Conduct.
We place tremendous importance on listening to our customers and being transparent with them. We believe the benefits of active engagement extends across all our stakeholder groups, and being transparent about all aspects of our performance is a vital part of building strong, long term relationships. As part of our commitment to transparency we intend to publish a separate, more detailed, CR report for the next financial year and aim to report in accordance with the core requirements of the Global Reporting Initiative (GRI) Standards.