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 health care professionals who use our products. Some countries where we operate have socialized health care, meaning most physicians work for state-owned entities and can be considered public officials. Edwards has long-held high standards for preventing corruption and bribery in connection with our external relationships so that these interactions remain appropriate.
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 the user’s perspective and advise product improvements that keep us at the forefront of innovation. Our most significant risks related to corruption occur through our financial relationships with physicians. It is important that these relationships do not bias (or appear to bias) our customers when making purchasing decisions regarding our products.
Reporting requirements vary by country and by nature of the transactions. Edwards also reports at the state or country level in several regions:
- Massachusetts – pursuant to law since 2011
- Vermont – pursuant to law since 2012
- France – pursuant to law since 2013
- Japan – voluntary report to meet industry code of conduct since 2014
- Romania – pursuant to law since 2015
- Australia – pursuant to industry association request in 2016
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 gifts or entertainment in pursuit of a business advantage. We detail these requirements on pp. 22– 23 of our Global Business Practices Standards. We also maintain 26 policies governing employee and supplier relationships with healthcare professionals, including policies on meals, gifts, entertainment, consulting, educational and research grants, discounts and rebates, and product training, among others. A significant number of these transactions require pre-approval by the Compliance Department.
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. We require annual certification renewals and due diligence renewals every two to three years.
Our corruption risk assessment covers 100 percent of our operations. In 2015, we also developed Anti-Corruption and Anti-Bribery Guidelines to supplement our Global Business Practices Standards. The guidelines further assist employees in making informed and ethical decisions by:
- 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 conduct training on these guidelines and require all employees with email accounts to certify compliance online.
Edwards continually improves our governance and policies for corruption and bribery. In 2016, we developed a specific code of conduct for third party sales intermediaries and required a key principal on behalf of the company to certify compliance. We provided new hire training on the Titanium Book and trained relevant employees on industry codes of conduct and healthcare compliance policies. In 2017, we will implement a risk-based due diligence process for all other third-party vendors. We will screen for risks related to anti-corruption and bribery, information security, environmental health and safety (EHS), labor, human trafficking, conflict minerals, privacy, quality, trade and legal issues, among others.