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Ethics and Compliance

Policies, Codes and Disclosures

All Hillrom associates, part and full-time, are required to complete Global Code of Conduct and Anti-Corruption training requirements every year:

Global Code of Conduct

This code—and other relevant policies and procedures—applies to everyone      employed by Hillrom and its global family of companies. Download Hillrom's Global Code of Conduct.

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 own Global Anti-Corruption Policy also applies to every Hillrom associate and those of our subsidiaries, suppliers, distributors and other global partners. Download Hillrom Global Anti-Corruption Policy.

The Global Third Party Code of Conduct

This details our requirements for third party distributors, suppliers, business partners and parties that register, promote, sell, or supply Hillrom products, or otherwise interact with government officials or health care providers on our behalf. Download Hillrom Global Third Party Code of Conduct

Interaction with Health Care Providers

This global policy provides specific guidance for associates on acceptable practices for marketing to, and interacting with, health care providers. Hillrom’s 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 with the United States Securities and Exchange Commission 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. 

Reporting

We encourage and expect employees to voice their concerns or file a report if they believe in good faith that a violation of law, regulation, other legal obligation, or policy or procedure is occurring, may occur, 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. 

Non-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, they should immediately report such potential retaliation to the Compliance Office or the Compliance Helpline for investigation.

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 potential management discrimination or harassment
  • Legal Department—Regarding laws and regulations related to Hillrom’s business
  • Finance Department—For finance or accounting issues
  • Global Compliance Office—Email directly via GlobalComplianceOffice@hillrom.com.  
  • Compliance Helpline—This is a tool for reporting concerns of real or potential misconduct. It is available 24 hours a day, seven days a week, with translators on staff. Where allowed by local law, reports can be made anonymously. All information received through the Compliance Helpline will be kept confidential to the extent that is possible and permitted by law. There are two ways to submit a report to the Compliance Helpline:

Answering your compliance questions and concerns is a top priority and we take these inquiries very seriously. We will promptly investigate the matter and, where appropriate, take disciplinary action and put measures in force to correct and prevent similar conduct.

The Hillrom whistleblower helpline and policy are communicated to employees on a regular basis all year through several platforms including, but not limited to, the following:  

  • Helpline posters visible in all physical locations
  • Communications from senior management
  • Videos
  • Online training
  • Live training sessions
  • Annual Compliance Week

Global Compliance Program

We’ve created and implement a comprehensive global compliance program designed to help maintain the highest professional and ethical standards. The Hillrom Chief Compliance Officer, 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 full- and part-time employees are required to complete annual Global Code of Conduct and Anti-Corruption Policy training.

Program Administration

Our Global Compliance Office—supported by Internal Audit, Legal and HR—reviews and audits the entire Hillrom 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 all regions and countries that need to be reviewed.  

Additionally, the Global Compliance Office performs integrity assessments on third parties that work on Hillrom’s behalf and are expected to interact with non-U.S. government officials or healthcare providers. Hillrom automatically re-checks third parties against worldwide databases and publicly exposed persons, sanctions and embargo lists on a monthly basis. Our strategic distributors are required to take Hillrom’s Distributor Compliance training annually and to re-certify to Good Business Practices.

Oversight

Our Global Compliance Committee meets quarterly and is comprised of senior officers of the company (including the CEO), as well as Regional Compliance Committees. The Global Compliance Office has specific responsibility for compliance program oversight and provides regular reports to the Audit Committee of the Board of Directors. 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.