Our reputation and integrity are central to Edwards Lifesciences' ability to be successful globally. Integrity is a key ingredient in building and maintaining our relationships as trusted partners, both internally and externally.
At Edwards, our people are committed to integrity, honesty, openness and fairness. Edwards' Global Business Practice Standards, what we call the Titanium Book, is a practical guide to help us with business practice issues we face as a dynamic, growing corporation. It helps explain the universal principles governing our business, provides clarity about expectations and identifies resources that support these standards. We ask each of our employees to read this document carefully to be sure they understand its content and are willing to embrace its principles. We also depend on each employee to exercise intelligence, common sense and good judgment as they apply the principles in their work.
Our reputation must be guarded carefully and reinforced continuously through our actions. Our employees' performance and commitment to conducting Edwards' business in a manner consistent with our Global Business Practice Standards and Our Credo are essential to Edwards' continued success.
Edwards Lifesciences has long been committed to doing the right thing. Compliance and ethics are a part of who we are and what we do. Our Board of Directors and senior leadership are committed to maintaining our ethical culture and give their unwavering support to our Global Integrity Program. As Edwards’ Chief Responsibility Officer, I oversee our compliance program. We strive to embed compliance in every aspect of our business. We challenge every employee worldwide to do the right thing and to lead by example. At Edwards, we recognize that success is built on integrity, and hold ourselves to the highest ethical standards. That is good business, and it is the right thing to do.
Edwards Lifesciences Corporation (“Edwards”) is committed to the highest standards of ethical conduct. To meet this commitment, Edwards has implemented this Global Integrity Program based upon recognized government standards for effective compliance programs, including guidance published by the Office of Inspector General, U.S. Department of Health and Human Services (the “HHS-OIG Guidance”).
The purpose of this Program is to detect and prevent behaviors, such as violations of law or company policy, which could harm Edwards and the people we serve. While the implementation of such a program cannot guarantee that improper employee conduct will be entirely eliminated, it is Edwards’ expectation that employees will comply with Program requirements, including the Edwards Global Business Practice Standards (“Standards”) and the policies and procedures established in support of the Standards. In the event that Edwards becomes aware of violations of law or company policy, we will investigate the matter and, where appropriate, take disciplinary action and implement corrective measures to prevent future violations.
The fundamental elements of our Global Integrity Program are described below. In accordance with the HHS-OIG guidance, we have tailored our Program to fit the unique environment, organizational structure, resources, operations and size of our company.Overview of Global Integrity Program
Edwards recognizes that compliance is a dynamic concept, so we constantly review and update our Program to improve it and make it more effective.Request a Copy
Request a Copy A copy of this Global Integrity Program and Edwards’ annual declaration of compliance may be obtained by calling 800-424-3278 (request the Compliance Department) or by contacting email@example.com .
As part of Edwards Lifesciences Corporation’s ongoing efforts in the area of compliance, we have developed a comprehensive compliance program referred to as the Edwards Global Integrity Program, which is designed to comply with applicable federal and state laws and industry standards relating to the marketing and promotion of our products. Edwards holds its employees responsible for compliance, and expects each employee to comply with its Global Integrity Program. While Edwards cannot entirely eliminate the chance of individual employees engaging in conduct defined as non-compliant by Edwards policy, Edwards has made and continues to make a good faith effort to promote its Global Integrity Program, to prevent incidents of non-compliance and to address any inappropriate conduct.
To our knowledge as of the date of this declaration, Edwards Lifesciences is in compliance, in all material respects, with such comprehensive compliance program, as described here, and with California Health and Safety Code sections 119400-119402.
A copy of the Edwards Global Integrity Program and this annual declaration of compliance may be obtained by calling 800-424-3278 (request the Compliance Department) or by contacting firstname.lastname@example.org.
Dated: September 1, 2016
Edwards Lifesciences has established various methods and resources for raising ethics questions and concerns, and encourages employees to “Speak Up” if they have a question or concern. These resources are outlined in our Global Business Practice Standards. One such resource is the Edwards Integrity Helpline, a reporting resource that is available 24 hours a day, 7 days a week. It is hosted by a third party. Any matter reported through the Helpline is treated confidentially and shared only with those that need to know for purposes of an investigation and, if appropriate, corrective action. Reports can be made to the Edwards Integrity Helpline anonymously, as permitted by local law. In certain countries, anonymous reporting is prohibited and Edwards may be required to reveal a caller’s identity.
Edwards strictly prohibits retaliation against any individual who reports a concern in good faith or participates in the company’s investigation of such a concern.
The Edwards Integrity Helpline can be accessed by telephone in the U.S. by dialing 877.219.3178. Telephone numbers and instructions for employees based in other countries are published on the Edwards employee intranet. Reports to the Helpline may also be made via the internet:
Providing innovative solutions for people fighting cardiovascular disease requires collaboration with health care providers. Edwards Lifesciences is committed to ethical and socially responsible business practices, and respects the obligation of health care professionals to make independent decisions regarding medical technologies. In addition to our Credo and core values of integrity and service on behalf of customers and patients around the world, Edwards has adopted industry codes of conduct that govern our interactions with health care professionals. In the United States, we play an active role in the Advanced Medical Technology Association (AdvaMed), and have adopted the AdvaMed Code of Ethics on Interactions with Health Care Professionals. Outside the United States, we have adopted similar codes of conduct. To learn more about these medical technology associations and the codes we have adopted, you may visit the websites listed above.
Edwards’ commitment to corporate citizenship and advancing the trust of our stakeholders, partners, and communities is long-held and strong. It begins with our Credo which guides our values, spirit, and conscience in everything that we do, and forms the framework for our Aspirations, which are the goals that inspire us every day. We look forward to refining our thinking on sustainability, identifying additional opportunities to enhance our practices, and continuing to report our progress.