Ethics & Compliance
Edwards Lifesciences’ work to manage Ethics and Compliance supports our Aspirations to Excel as a Trusted Partner and Global Leader Through the Quality of Our Work and Create Exceptional Shareholder Value.
At Edwards Lifesciences, our commitment to ethics shapes all that we do. We build our success from a foundation of integrity and have long been dedicated to doing the right thing. In our work to develop life-saving therapies, our leadership and employees know every decision matters, no matter how small. We hold our team to the highest ethical standards, strengthening Edwards’ reputation as a trusted partner.
Global Integrity Program
The purpose of Edwards’ Global Integrity Program is to detect and prevent behaviors that could harm our company and the people we serve. It includes written policies, communication channels, employee training and audits and monitoring to ensure compliance.
Our Chief Responsibility Officer (CRO) oversees daily implementation and typically reports monthly to our Executive Leadership Team (ELT) and quarterly to the Board of Directors. Our future goal is to conduct leadership training on making ethical decisions in 100% of Edwards Lifesciences Leadership Program courses. We believe a culture of integrity exists only when each employee makes ethical decisions in their daily interactions.
Our Corporate Compliance Committee provides support and guidance to the CRO. Comprised of executive team members, including business unit leads and functional heads, the Committee meets quarterly to discuss progress. In addition, our regional compliance officers chair regional committees that oversee compliance at a local level.
Global Business Practice Standards
Edwards strives to be transparent regarding our standards for ethics and compliance. We make our Global Business Practice Standards, also known as the “Titanium Book”, publicly available on our website. The Standards outline ethical behaviors to which all employees and third-party contractors must adhere. These include interactions with health care professionals, quality control practices, intellectual property and patient privacy. We promptly investigate any reports of misconduct and take appropriate disciplinary action. Edwards’ Board of Directors receives a quarterly briefing of all reports and findings.
All new employees receive a copy of the Titanium Book and must certify they have read it and agree to abide by all applicable laws, industry codes and company policies relevant to their work. We mandate online training on the Titanium Book upon hire, and bi-annually thereafter. Through this online training, we aim to ensure 100 percent of our employees certify to understanding and agree to comply with these standards.
All professional employees must also complete an annual online certification, reinforcing their commitment to the Standards. We conduct this process in multiple languages, including Chinese, English, French, German, Japanese, Portuguese and Spanish. In conjunction with the certification, we survey professional employees on topics such as fear of retaliation and whether they have reported misconduct. Our future goal is to achieve 100 percent certification from professional employees every year.
Edwards Integrity Helpline
Our goal is to create a culture of trust so all employees feel comfortable sharing their concerns. The Edwards Integrity Helpline is available 24/7 for both United States and international employees. The Integrity Helpline is hosted by a third party. We treat all reports as confidential and share only with those participating in the investigation and, if appropriate, corrective action.
We treat each concern seriously and with equal respect, care and consideration for all involved. We strictly prohibit retaliation against any individual who reports a concern in good faith or participates in the company’s investigation.
Compliance with Industry Codes
Edwards’ collaboration with physicians is essential for the continued innovation of our technologies and therapies. We align our internal ethics standards with country-specific industry codes of conduct and require adherence by all of our representatives. These organizations include:
- AdvaMed (U.S. and China)
- Canada’s Medical Technology Companies
- Amid (Mexico)
- Korea Medical Devices Industry Association
- Medical Technology Association of
- Taiwan Code (TAMTA)
- MedTech Europe (Europe)
- Abimed (Brazil)
- Asociacion Nacional de Empresarios
- The Japan Federation of Medical
- Medical Technology Association of Australia
- Thai Medical Device Technology
Edwards continually strives to improve our culture to promote ethical business practices, trust and good decision-making. We require all professional employees to complete an annual online certification, reinforcing their commitment to our Global Business Practice Standards. In 2015, this included 2,544 professional employees, representing 46 percent of our total population. For those certifying, we achieved a 98 percent participation rate and did not ask employees on leaves of absence to respond. Less than one percent indicated they did not feel comfortable openly discussing ethical or business practice concerns without fear of retaliation. We followed up with 100 percent of employees surveyed who indicated a concern.
Also in 2015, we held our 3rd annual Compliance Day in over 15 sites worldwide and issued more than 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.
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.