Code of Business Conduct
III. Honest and Ethical Conduct
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Principle 1: Fair Dealing
We will deal honestly and ethically with Abbott and on Abbott's behalf in
all matters.
We will deal honestly and ethically with Abbott and with Abbott’s customers,
suppliers, competitors, employees and other stakeholders.
We will treat people fairly. We must not take unfair advantage of anyone
through manipulation, concealment, abuse of privileged or otherwise undisclosed
information, misrepresentation of material facts or any other unfair–dealing
practices.
Principle 2: Avoiding Conflict of Interest
We will avoid actual or apparent conflicts with Abbott's
interest.
A conflict situation can arise when one of us takes action or has interests
that may make it difficult to perform our Abbott work objectively and
effectively.
We must avoid any investment, interest, or association that interferes or
might interfere with the independent exercise of our own individual best
judgment, and with our obligation to perform our responsibilities in the best
interests of Abbott.
For example:
- We will deal with all suppliers, customers, and all other persons doing
business with Abbott in a completely fair and objective manner without favor or
preference based upon personal financial or relationship considerations.
- We will not accept from or give to any supplier, customer, or competitor
any gift or entertainment except as allowed under “Gifts, Meals and
Entertainment” (Principle 5: Accuracy and Integrity of
Books, Records and Accounts).
- We will not do business on behalf of Abbott with a member of our household
or a close relative, unless the transaction is disclosed, in writing, to the
Office of Ethics and Compliance, which determines that the transaction is on
arms–length terms and is consistent with the purposes of this Principle.
A close relative would include, for example, at a minimum, a spouse, domestic
partner, parent, parent–in–law, sibling, sibling–in–law, child or
son/daughter–in–law, or stepparent, stepsibling, or stepchild.
- We will not, directly or indirectly, have a financial interest in any firm
or company which is a competitor of Abbott if such financial interest
represents a material percentage of the total net worth of the officer or
employee, or if such ownership creates a direct conflict of interest for the
officer or employee in connection with work the officer or employee is
performing for Abbott.
- We will not, directly or indirectly, have a financial interest in or hold
any employment, managerial, directorial, consulting or other position with any
firm or company which does or seeks to do business with Abbott, if such
interest or position may influence any decision that we might make in the
performance of our regular duties.
We must disclose to the Corporate Officer responsible for our function the
existence of any such interest or position, whether actual or proposed. The
Corporate Officer will review such case with the Office of Ethics and
Compliance, and they will determine whether the existence of such interest or
position is or may be in conflict with this Principle or otherwise detrimental
to the best interest of Abbott or any of its operations. If they determine that
such conflict or detrimental effect may occur, such steps as are necessary to
correct the situation will be immediately taken.
- Loans from Abbott to, or guarantees by Abbott of obligations of, officers
and employees and their respective household members and close relatives may
create conflicts of interest. United States law prohibits personal loans from
public corporations to directors and executive officers.
Principle 3: Abbott Opportunities
We will advance Abbott's business interests when the opportunity to do so
arises.
When presented with opportunities related to Abbott’s business interests, we
must first offer those opportunities to Abbott. We will not: (a) take for
ourselves personally, or for members of our household or close relatives,
opportunities that are discovered through the use of Abbott property,
information or position; (b) use Abbott property, information, or position for
personal gain; or (c) hold any employment, managerial, directorial, consulting
or other position with any firm or company which is a competitor of Abbott.
Principle 4: Gifts, Meals and Entertainment
We will comply with Abbott's standards, policies and procedures regards
gifts, meals and entertainment.
We will not seek, accept, offer, promise, or give (directly or indirectly)
anything of value—including payments, fees, loans, services, entertainment,
favors or gifts—from or to any person or firm as a condition or result of doing
business with Abbott.
Subject to that general prohibition and to the additional policies and procedures referred to in this
principle:
- Abbott’s policy is intended to permit gifts of reasonable value, normal
business meals and entertainment, the exchange of customary reciprocal
courtesies between employees of Abbott and their business associates, and
similar customary and reasonable expenditures to promote general business
goodwill; and
- Reasonable expenditures for gifts to, meals for, and the entertainment of
business contacts may be made if the expenditures are appropriate and are
correctly recorded on the books of the paying entity.
Additional policies and procedures
apply in certain situations, such as the following:
For gifts, meals and entertainment involving
suppliers, see Abbott’s Corporate Purchasing Policies.
For gifts, meals and entertainment involving health care professionals
and other customers, see the Divisional Operating Procedures for
Program Funding (formerly “Operating Guidelines for Program Funding”) in the
United States and Puerto Rico, and local policies and procedures in other
countries.
For gifts, meals and entertainment involving government officials or
employees, this Principle is subject to the provisions of “Laws
Relating
to Payments to Government Officials/Employees” on page 19, as well as the
Divisional Operating Procedures for Program Funding in the United States and
Puerto Rico, and local policies and procedures in other countries.
Principle 5: Accuracy and Integrity of Books, Records
and Accounts
We will ensure the accuracy and integrity of Abbott's books, records and
accounts.
All Abbott books, records and accounts must accurately reflect the nature of
the transactions recorded.
Books and records include but are not limited to ledgers, vouchers, bills,
invoices, time sheets, expense reports, payroll and benefits records and other
essential company data.
All assets and liabilities of Abbott must be properly recorded in the
regular books of account.
No undisclosed or unrecorded fund or asset shall be established in any
amount for any purpose.
No transaction or arrangement shall be structured to circumvent Abbott’s
internal control system.
No false or artificial entries shall be made for any purpose.
No payment shall be made, nor purchase price agreed to, with the intention
or understanding that any part of such payment is to be used for any purpose
other than that described in the document supporting the payment.
With respect to reporting of complaints or concerns regarding accounting,
internal accounting controls, or auditing matters, see
Disclosure Programs.
Principle 6: Protection of Confidential Information of
Customers and Others
We will protect the confidential information of customers, suppliers and
other parties which we receive in the course of conducting Abbott
business.
We must not accept non–public information provided by a customer, supplier
or other party with the condition or understanding that it be kept confidential
unless such information is subject to a written confidential disclosure
agreement or confidentiality provision drafted or approved by the Legal
Division.
We must maintain the confidentiality of information entrusted to Abbott by a
customer or other third party, except when disclosure is legally mandated as
determined by the Legal Division.
We must not seek or accept confidential information of or about a competitor
in an illegal or unethical manner.
If we have confidential information about a former employer or any other
entity with which we were previously affiliated, we are expected to abide by
our obligation to keep such information confidential. Abbott will not require
and does not want us to use or disclose such information in our capacity as an
officer or employee of Abbott.