Guidance and Compliance
Open communication is at the core of Baxter’s commitment to integrity. Managers are responsible for maintaining an environment that enables employees to safely raise and discuss issues. Baxter encourages employees to seek guidance and report concerns through a number of formal channels (see graphic). Through these channels, Baxter prevents incidents from occurring and addresses issues when they do arise.
One such channel is the Baxter Ethics and Compliance Helpline, a telephone and Web resource available to employees, their families, suppliers and customers. Callers can report an issue or seek guidance in their local language. Counselors are available in 150 languages, 24 hours a day, seven days a week.
In 2008, 225 inquiries were received through the Helpline. Additionally, the Certificate of Integrity and Compliance (COIC) process identified 48 issues requiring follow-up by Ethics and Compliance staff. Of the 273 inquiries received through these two channels (see table), 143 were related to ethics and compliance. All inquiries received were addressed.
Items identified through the Helpline, COIC process and other channels help Ethics and Compliance managers identify key risks, develop appropriate training, and design and apply compliance assessment methodologies.
| ETHICS AND COMPLIANCE HELPLINE AND CERTIFICATE OF INTEGRITY AND COMPLIANCE INQUIRY TOPICS, 2008 | |
| Accounting and Auditing Matters | 11 |
| Advertising or Promotional Materials—Off-Label Use | 2 |
| Ask a Question or Request Assistance | 26 |
| Best Price and Other Price Reporting | 1 |
| Bribes, Kickbacks, FCPA Violations, or Other Corrupt Practices | 15 |
| cGMP – Current Good Manufacturing Practices | 1 |
| Clinical Trials | 2 |
| Conflicts of Interest | 22 |
| Data Privacy | 3 |
| Disclosure of Confidential Information | 3 |
| Discrimination or Harassment | 14 |
| Embezzlement, Theft or Fraud | 8 |
| Environmental Protection, Health or Safety Law | 10 |
| Failure to Comply with Quality, Regulatory, or Manufacturing Standards | 16 |
| Falsification of Contracts, Reports or Records | 9 |
| Gifts and Entertainment | 12 |
| Grant Misconduct (Research or Educational) | 2 |
| Improper Lobbying or Political Contributions | 2 |
| Improper Supplier or Contractor Activity | 1 |
| Inquiry | 3 |
| Insider Trading or Other Securities Violation | 1 |
| Intellectual Property Infringement | 1 |
| Misconduct or Inappropriate Behavior | 58 |
| Misleading Sales, Marketing and Advertisement | 3 |
| Misuse of Assets or Services | 1 |
| PhRMA Code on Interactions with Healthcare Professionals | 1 |
| Questionable Discounts | 1 |
| Retaliation | 2 |
| Substance Abuse | 1 |
| Other | 41 |
| Total | 273 |
