Corruption & Bribery
Edwards Lifesciences’ work to prevent Corruption and Bribery supports our Aspirations to Excel as a Trusted Partner and Global Leader Through the Quality of Our Work and Create Exceptional Shareholder Value.
The nature of our work means Edwards Lifesciences regularly interacts with healthcare professionals who use our products. Some countries where we operate have socialized healthcare, meaning most physicians work for state-owned entities and can be considered public officials. To ensure these interactions remain appropriate, Edwards has long-held high standards for preventing corruption and bribery in connection with our external relationships.
Edwards conducts business consistently in all countries. We require all employees, as well as agents acting on Edwards’ behalf, to adhere to the following government regulations for preventing corruption:
- The U.S. Foreign Corruption Practices Act
- The U.K. Bribery Act
- All applicable local and regional laws, including anti-corruption and anti-competition laws
Financial Relationships with Physicians
Collaboration with medical experts provides immense value to our research and development efforts. Physicians can offer insight from a “ground level” and advise product improvements that keep us at the forefront of innovation. Our most significant risks related to corruption are financial relationships with physicians.
Reporting requirements vary by country and by nature of the transactions. Edwards also reports at the country and state level in several locations:
- Massachusetts – pursuant to law since 2011
- Vermont – pursuant to law since 2012
- Japan – voluntary report to meet industry code of conduct since 2014
- France – pursuant to law since 2013
- Romania – pursuant to law since 2015
Edwards is committed to a free and competitive global marketplace. We believe buyers should be able to select from a variety of products at competitive prices. Edwards does not condone any form of gifts or entertainment in pursuit of a business advantage. We detail these requirements on pp. 22–23 of our Global Business Practices Standards.
Third-Party Anti-Corruption Training
In 2014, Edwards expanded due diligence and anti-corruption training to our global third-party sales intermediaries. We continued these efforts in 2015 and 2016. Following review, we require annual certification renewals and due diligence renewals every two to three years.
Edwards continually improves our governance and policies for corruption and bribery. In 2015, our corruption risk assessment covered 100% of our operations. We also developed Anti-Corruption and Anti-Bribery Guidelines to supplement our Global Business Practice Standards. They further assist employees in making informed and ethical decisions by the following:
- Explaining the importance of compliance and requiring employee adherence
- Defining improper payments or bribes, including examples and red-flags
- Defining who is considered a government official in our industry
- Explaining how to work with third parties acting on our behalf, including appropriate due diligence prior to engagement
- Identifying the need to maintain accurate books and records
- Explaining the need for appropriate diligence in mergers, acquisitions and joint ventures
We conducted training for these guidelines in 2015, and required all employees with email accounts to certify compliance online. We also continued to conduct due diligence and anti-corruption training for our third-party sales intermediaries.
Notably, in 2015, we held our 3rd annual Compliance Day in over 15 sites worldwide. We issued over 4,000 raffle tickets to both corporate and manufacturing employees. Each location chose a theme, which included: Reminding employees to speak up and report concerns; Compliance with quality and industry code standards; and, Following our Global Business Practice Standards.
Feedback for our 2015 Compliance Day was positive and enthusiastic. This year, employees from around the world submitted ethics-themed “memes” to reinforce our commitment.