Compliance and ethics

The Code of Conduct serves as a foundation for our existing policies and rules. We use the Code of Conduct to help ensure that integrity and ethics in all business relationships are maintained while simultaneously striving for high customer satisfaction and to encourage ethical discussions and improve how we address ethical dilemmas. Acting with integrity is about more than our image and reputation or avoiding legal issues. It’s about sustaining a place where we are all proud to work.

Download Code of Conduct - English (PDF)

The Code is also available to you in each of the languages listed below (PDF).

Boston Scientific provides several resources that employees and others can use to ask a question, obtain guidance or report a Code of Conduct concern. Boston Scientific strongly encourages use of these resources. One of the resources for reporting concerns is our Advice Line.

The Advice Line allows anyone to ask a question, raise a concern or file a report relating to integrity at Boston Scientific. The Advice Line is managed by a third-party vendor. If you have an ethics or compliance question or an inquiry regarding a company policy, you can ask anonymously and confidentially.

The Advice Line can also be accessed via a toll-free telephone number that anyone can call, 24 hours a day, seven days a week. The Advice Line handles calls in multiple languages. The toll-free number is 888-968-8425.

The Advice Line allows anonymous reporting, except where local law restricts it. For additional information about calling the Advice Line, see Code of Conduct, page 49.

Note: The Advice Line is not designed for reporting product complaints. If you are not a Boston Scientific employee and need to report a product complaint, please call Customer Service at 888-272-1001. Boston Scientific employees, please follow corporate complaint reporting guidelines. Please visit our Advice Line Portal.

It is our employees’ responsibility to immediately raise any integrity concern or suspected violation of the Code, company policy or procedure. See Code of Conduct, page 8.

Boston Scientific does not tolerate any form of retaliation against an individual arising from a good-faith report of a potential violation of our Code of Conduct, a related policy or of an integrity concern. Retaliation is also prohibited against anyone who assists with, or cooperates in, an investigation of such a report.

The fundamental elements of our compliance program are described below. Note that our compliance program is constantly evolving to meet the changing needs and demands of the compliance environment and of Boston Scientific.

The company’s Global Compliance Program is led by our Vice President and Chief Compliance Officer, who makes periodic reports to the Boston Scientific Board of Directors. The program also includes Compliance Committees, which have been established by division and in various regional and country-level sales offices. The Compliance Committees include participation by senior leadership to provide strategic direction and oversight relating to the management of compliance risks for the company.

Our Code of Conduct is a cornerstone of our compliance program and provides guidance on business conduct and practices to all Boston Scientific team members. While the implementation of a compliance program cannot guarantee that all improper employee conduct will be eliminated, it is the expectation of Boston Scientific that each of our team members will comply with our Code of Conduct and the policies that have been established in support of that code.

Boston Scientific is committed to fostering effective lines of communication between management and employees. Employee training and education programs increase awareness of the legal and ethical implications of abiding by our Code of Conduct and related policies and making sound and ethical business decisions. We monitor the nature of inquiries that our compliance program receives and make appropriate adjustments, as needed, to our training and communications.

The Boston Scientific compliance program includes ongoing efforts to monitor, assess and audit compliance with our Code of Conduct and related policies. Our compliance program has a dedicated group that conducts both cause and risk-based audits and also works with our internal financial audit function to monitor compliance, identify potential problem areas, and support preventative measures and corrective actions.

Boston Scientific aims to respond promptly and impartially to questions, concerns and reports of potential violations of our compliance program. We have implemented policies and processes for the prompt and proper investigation of such reports. With regard to complaints received concerning accounting, internal accounting controls or auditing matters, Boston Scientific has established a process to escalate matters to the Audit Committee of the Board of Directors, as appropriate.

The Boston Scientific compliance program includes clear policies that set out the consequences of violating the law, our Code of Conduct and related policies. Although each situation is considered on a case-by-case basis, Boston Scientific consistently undertakes appropriate corrective action to address inappropriate conduct and to deter future violations.

Many changes in laws and ethical codes that govern interactions between industry and physicians and other health care providers have occurred since Boston Scientific was founded.

Boston Scientific was an early supporter of the Medtech Canada Code of Conduct and remains a strong supporter of this important industry code. We respect the obligation of physicians and other health care providers to make independent decisions that are in the best interest of patient care. Selection of medical devices should be based solely on their effectiveness, quality and value.

Boston Scientific seeks to act ethically in our business practices, comply with local tax and business laws and regulations, and be transparent in our reporting. We extend these practices to our operations as well as to our customers, suppliers and communities in which we operate.

Policy Statement on Anti-Corruption

Boston Scientific is committed to acting ethically in dealing with customers, employees, shareholders, partners, suppliers, competitors, and the community and with respect for applicable laws. One way that we make this happen is through the implementation of our Global Compliance Program, and our Code of Conduct, both of which are discussed in more detail in the Compliance and Ethics portion of our internet site. The primary purpose of our compliance program is to detect and prevent violations of laws, regulations, and company policies, taking into account and tailoring the program to our unique environment.

Due Diligence of New Channel Business Partners – Corruption and Bribery

As part of Boston Scientific’s commitment to acting ethically in all matters and with respect for all applicable laws, due diligence is conducted of new channel business partners, during which time Boston Scientific looks to partner with other entities that demonstrate a similar commitment to acting ethically in these matters.

Communication of Anti-Corruption Policy to Employees

The Corporate Citizenship section of Boston Scientific’s company website clearly communicates the company’s commitment to acting ethically in all dealings.  This website reflects the information communicated to our employees through formal training and knowledge-based testing, as well as via direct email.

Training on Anti-Corruption

Employees are required annually to complete a training course on ethics and compliance, including a section on anti-corruption.

Corruption Risk Assessments for Company Operations

As part of our standard audit process, operational risks are assessed, including those at risk of corruption.

Procedures to Address Corruption

Our Code of Conduct is about acting with integrity by treating people honestly and with respect, both inside and outside of Boston Scientific.  This Code lays out clear guidelines for dealing with corruption, as well as various means to ask a question or confidentially raise a concern should a related issue arise.

Compliance with Anti-Corruption Requirements

Boston Scientific maintains policies and procedures reasonably designed to comply with compliance and anti-corruption rules and regulations.  Violations of such policies may lead, and has led, to discipline up to and including termination.