Operating Globally, Acting Locally

Understanding and adhering to local laws, regulations and other requirements is vital for our employees no matter where they work. The Affiliate Compliance Program was designed to formalize compliance programs, including distinct policies and procedures in each of the countries where Abbott operates. In 2007, we improved local implementation of the ethics program through better information sharing, training and awareness across the business. The International Compliance Web site provides direction and guidance to help employees understand and operate in compliance with local policies and procedures.

California Comprehensive Ethics & Compliance Program and Declaration

Abbott continued the rollout of its global ethics and compliance programs at all of its international affiliates. The Affiliate Compliance Program (ACP) is managed by the local Affiliate Compliance Committees (ACC), is composed of the general manager and other top executives, representing all of Abbott's businesses within a country. The Affiliate Compliance Committees are responsible for the day-to-day function of the compliance program, including identifying gaps in the program, revising policies and procedures, and providing guidance to local employees. The committees also meet on a regular basis to discuss emerging issues, and work with Regional OEC Directors as new programs initiated by the Office of Ethics and Compliance are rolled out. OEC Regional Directors are located throughout the world and provide oversight and guidance to the Affiliate Compliance Committees.

One of our major efforts in 2008 was the ongoing expansion of our Global Event Planning Tool (GEPT). This Web-based tool was developed to assist all Abbott employees worldwide when planning cross-border events with customers, including health care professionals. The GEPT allows employees to plan events in compliance with each country's ACC policies.

The affiliates are audited against the Affiliate Compliance Program and the applicable policies and procedures. This audit function has been added to ensure that the affiliates are in compliance with local ethics and compliance policies and procedures.

We offer a number of resources to employees, such as Abbott's Ethics and Compliance Helpline, a telephone and Web-based hotline available 24 hours a day, seven days a week.