Governance
Sustainability Report > Governance > Corruption & Bribery
SUSTAINABILITY REPORT

Corruption & Bribery

G4-DMA
Management approach

G4-SO3
Operations assessed for corruption risks

G4-DMA
G4-SO3

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.

DEFINITION
Enacting management practices and policies to prevent corruption and bribery at Edwards

MANAGEMENT APPROACH
ANNUAL PERFORMANCE

Management Approach

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.

Edwards is transparent about the nature of these relationships and their benefit to all. In 2008, Edwards became the first of our peers to voluntarily publicly disclose all financial interactions with physicians in the United States. Now, in accordance with the U.S. Affordable Care Act., we report all financial relationships with physicians and teaching hospitals through the Open Payments system on the Center for Medicare and Medicaid Services website.

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.

Annual Performance

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:

  1. Explaining the importance of compliance and requiring employee adherence
  2. Defining improper payments or bribes, including examples and red-flags
  3. Defining who is considered a government official in our industry
  4. Explaining how to work with third parties acting on our behalf, including appropriate due diligence prior to engagement
  5. Identifying the need to maintain accurate books and records
  6. 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.

Our Aspirations

Excel as a Trusted Partner and Global Leader Through the Quality of Our Work

Create Exceptional Shareholder Value


MATERIAL TOPICS

RELATED RESOURCES

Financial Relationships with PhysiciansOpen PaymentsGlobal Business Practice Standards
HIGHLIGHT STORY
Driving a Culture of Ethics with Compliance Day
Each year, Edwards holds a Compliance Day at each of our major locations and encourages all employees to participate. Compliance Day reminds us of the Titanium Book principles and our obligation to report misconduct. Throughout the day, we hold activities related to ethics and compliance and provide employees food, games, puzzles and giveaways.
 
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.
DEFINITION