The Code of Conduct is a cultural conduit
MEDIRONIC’s Code of Conduct is one of the Company’s most important policy documents for responsible enterprise and serves as a conduit for the Company’s culture. It clarifies the fundamental principles by which MEDIRONIC expects each employee and partner – such as suppliers and distributors – to abide. The Code includes comprehensive information concerning MEDIRONIC’s view of its responsibility in terms of social, environmental and financial matters. The areas of responsibility described include, for example, employee rights, product safety, corruption, conflicts of interest and competition.
MEDIRONIC’s Code of Conduct adheres to principles established by international bodies, such as the UN Declaration on Human Rights, the UN Global Compact, the OECD Guidelines for Multinational Enterprises and the ILO Declaration on Fundamental Principles and Rights at Work. The Code of Conduct is kept alive in many ways, including having all senior executives sign the Code on an annual basis. The Code plays a key role during the integration of new acquisitions.
Supplemental anti-corruption policy
MEDIRONIC’s anti-corruption policy serves as an important supplement to the Code of Conduct. The cornerstone of the policy is zero tolerance for corruption. A substantial portion of the policy focuses on the interaction with health care personnel and with MEDIRONIC’s other clients, agents and distributors. The rules cover a wide range of improper behavior that could damage MEDIRONIC’s credibility in such areas as consultancy agreements, gifts, donations and research agreements.
The anti-corruption policy has been translated into several languages and all employees are to study it using an e-learning program. The policy applies to all companies and employees of the MEDIRONIC INC,. It is also to be communicated and applied in all contractual relations with MEDIRONIC’s business partners.
Ultimate responsibility for informing employees and partners about the Code of Conduct and the policy rests with the management of each of the Group’s legal entities. The Group’s Head of CSR is in charge of implementing and monitoring compliance through such measures as regular audits. Serious incidents are to be reported directly to the CEO and the Board of Directors. A whistleblower procedure enables employees to turn directly to the Head of CSR if they suspect improprieties, without risking sanctions.
International partnerships
MEDIRONIC is also a member of a number of industry organizations that have produced sector-wide Codes of Conduct, such as COCIR in Europe and MITA in the US. These Codes also clarify the rules that should apply in the Company’s relationships with decision-makers and clients in the care sector, including physicians, nurses, hospital managers and consultants appointed by hospitals.
Authorities and legislation
MEDIRONIC’s employees and suppliers must always comply with the prevailing legislation and the regulations and international conventions that apply in the countries in which MEDIRONIC ,conducts operations or maintains contact.
MEDIRONIC respects and complies with competition regulations, environmental legislation, labor laws, safety requirements and other provisions that are relevant to its operations. MEDIRONIC also engages in a regular dialog with authorities and legislators through its membership in various industry organizations. For its financial activities, MEDIRONIC complies with all accounting legislation and regulations to guarantee correct and transparent information regarding the Company’s operations, structure, financial position and performance.