Standards of
Business Conduct
Dear Colleague:
Wherever you live and work as part of our global Cardinal Health team, we
recognize the important role we play in healthcare. Our products and services
help our customers deliver the highest standards of care to patients, ultimately
improving (and often saving) lives. These customers count on us to provide
safe, secure, efficient and effective solutions – to build connections across the
continuum of care, to deliver end-to-end offerings and data-driving insights to
advance the industry, to address complex healthcare challenges, and more.
When we conduct our business in the right way, we help our customers
succeed… and we create value for all of our stakeholders. Ethical and
compliant behavior is a core imperative for us; we care deeply about our
employees, our customers, our communities, and one another.
The Standards of Business Conduct is the basic reference tool available to
every employee around the world. It’s important for each of us to be familiar
with its contents, as it guides us to behave with integrity; help us more fully
understand our commitment to delivering high-quality, safe and effective
products and services; illustrates the importance of cultivating a work
environment that fosters respect, honesty and accountability; and more.
As a member of our Cardinal Health team, you are responsible for
reading the Standards of Business Conduct with an eye toward how it
applies to your work. We expect you to put the concepts into action
as situationally appropriate for your role, and also to re-visit the tool to
retain your familiarity with it as needed.
The concepts of integrity outlined in the Standards of Business
Conduct extend to anyone working on behalf of Cardinal Health,
including consultants, contractors and other third-party business
partners. The Cardinal Health Vendor Code of Conduct and Anti-
Bribery and Corruption Guidelines are companion pieces to the
Standards of Business Conduct. Each of these documents outline
our principles and expectations for those who supply goods and
services to us or on our behalf.
I encourage you to speak up, raise concerns and always do the
right thing. We can all be proud of working for an organization
committed to following the highest ethical and business standards.
Sincerely,
A letter from the CEO
Jason Hollar, CEO
1
www.businessconductline.com
Our Values are
what we believe
Our Behaviors are
how we act
Explores possibilities for the future
Seeks connections for the greater good
Invites
curiosity
Builds
partnerships
Develops self
and others
Inspires
commitment
Pursues results with passion
Inspires others to grow to our
full potential
We hold ourselves to the
highest ethical standards
We embrace differences to
drive the best outcomes
We develop new ways of thinking,
operating and serving customers
We bring passion, determination and
grit to deliver on our commitments
We serve the greater goal
of healthcare
Mission driven
www.businessconductline.com
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Integrity.
Innovative
Accountable.
Inclusive
Table of contents
Overview
4
Standards of Business Conduct summary
5
Act with integrity and in compliance with the law
6
What we expect of our employees
7
What we expect of our leaders
7
Ask questions, seek guidance and raise concerns
8
Ethics and Compliance department
9
Business Conduct Line
9
No retaliation
9
A word about investigations
9
Accounting, auditing and internal controls
or financial reporting
10
Other matters, including ethical, quality and legal
and regulatory compliance matters
10
Treat one another fairly and foster a safe,
productive, diverse and environmentally
responsible workplace
11
Environment, health and safety
12
Fair treatment and diversity
12
Harassment and bullying
12
Substance abuse
12
Workplace violence prevention
12
Avoid conflicts of interest
14
Conflicts of interest
15
Restrictions on buying and selling stock and securities
(insider trading)
15
Compete with integrity in the marketplace
16
Competitive intelligence
17
Interactions with consultants, contractors and other
business partners
17
Interactions with competitors (fair competition and antitrust)
17
Interactions with customers
17
Marketing practices
18
Purchasing practices
18
Protect the integrity of the global supply chain
19
Quality
20
Anti-diversion compliance
20
Trade regulations
20
Money laundering and terrorist financing
21
Interact appropriately with government
entities, officials and employees
22
Audits and investigations
23
Interactions with government-related customers
23
Bribery and corruption prevention
23
Interactions with elected officials/
political contributions and lobbying
24
Maintain accurate books and records
25
Books and records
26
Communication
26
Authority to act on behalf of Cardinal Health
26
Protect information and assets
28
Confidential information
29
Personal use
29
Personal information
30
Intellectual property
30
Records management
30
Encourage individual volunteerism and
corporate social responsibility
32
Individual volunteerism
33
Corporate social responsibility
33
Business Conduct Line telephone numbers
34
Resource list
34
Business Conduct Line 800.926.0834
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The Standards of Business Conduct outlines what is expected of every
employee, officer and director of Cardinal Health. It is essential that we
commit to complying not only with the letter but also the spirit of these
standards. Although the Standards of Business Conduct covers some
examples of ethical and business issues and scenarios, a single document
cannot provide all the answers. Additional guidance is provided in the form
of policies and procedures. Please be aware that just as industry standards
and legal and regulatory requirements evolve, our standards, policies
and procedures are amended from time to time. For the most current
information, you should visit our internal website, my.cardinalhealth.net.
The information you see posted is the most up to date and is considered
immediately effective upon posting. We encourage all employees to visit
the intranet periodically to keep current.
If you have any uncertainty or questions regarding the application of these
standards, you should contact your manager, the Ethics and Compliance
department or the Business Conduct Line. Anyone who fails to adhere
to the Standards of Business Conduct, our policies and applicable laws
is acting outside the scope of his or her employment or engagement
with the company and may be subject to discipline, up to and including
termination of employment. That person may also face civil fines and
criminal penalties.
When conducting business for or on behalf of Cardinal Health, consultants,
contractors and other business partners are required to observe the same
level of integrity, responsible business conduct and compliance with the
law as Cardinal Health employees. Employees should provide such third
parties with a copy of the Vendor Code of Conduct, which is available at
cardinalhealth.com.
Any waiver of a provision contained in this document requires the written
approval of the Chief Legal and Compliance Officer. In addition, any waiver
requested for an executive officer or director requires the approval of the
Risk Oversight Committee of the Board of Directors and prompt disclosure
to shareholders.
The Standards of Business Conduct is available in multiple languages and is
accessible via mycardinalhealth.net and the external website as a publicly
accessible document. Company wide policies and procedures described
Overview
in this booklet are posted on the intranet. If you have any questions or
concerns, please talk with your manager, or call the Ethics and Compliance
department or the Business Conduct Line. All telephone numbers are
listed at the back of this booklet. You may also contact any of the other
resources listed at the back of this booklet.
At Cardinal Health, we are committed to a culture where each employee
makes wise decisions that consistently reinforce that our customers,
suppliers, investors and fellow employees can trust us to do the right thing.
Trust is the degree of confidence stakeholders have in the people who
make the day-to-day decisions in a company; it determines reputation and
drives results.
A key to a culture of trust is to make sure that each employee knows,
understands and follows a core set of shared values and conducts himself
or herself consistent with standards based on those values. The Standards
of Business Conduct is our common set of standards. What we do defines
who we are and our Standards of Business Conduct defines how we can
be expected to behave at Cardinal Health.
When making work-related decisions,
employees should ask themselves:
Can I take a particular action? Should I take that action?
The “can I” question asks whether it’s permissible to take a particular action
based on an analysis of the law, applicable regulations, our Standards of
Business Conduct and Cardinal Health policy.
The “should I” question goes a step further, asking whether the action
is advisable. It questions how the action will be viewed down the road
through the lens of hindsight and seeks to determine the future impact
of that decision on Cardinal Health’s reputation with key stakeholders,
government regulators and the public. Our Standards of Business Conduct,
our internal policies and the law frame the “can we” question; our values
frame the “should we” question. In short, our Standards of Business Conduct
and values work together so our employees know what is expected of
them as we seek to serve our customers and enhance our reputation as a
company of people who can be trusted to do the right thing.
We are pleased to provide the
Standards of Business Conduct
which describes the values and
standards we live by at Cardinal Health. In addition, the Ethics and Compliance Department
maintains specific policies and procedures — all available online or on request — that provide
a detailed view of company expectations for situations you may encounter. Maintaining our
Standards of Business Conduct
is a responsibility we share as employees of Cardinal Health.
www.businessconductline.com
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1.
Act with integrity and in compliance with the law
We work together, according to shared standards and values, to make wise decisions that foster
a culture of trust and responsible business conduct. We expect the same from consultants,
contractors and other third party partners who conduct business with us or on our behalf.
2.
Ask questions, seek guidance and raise concerns
We ask questions, seek guidance and raise concerns in
order to work together with confidence and trust.
3.
Treat one another fairly and foster a safe, productive,
diverse and environmentally responsible workplace
We treat one another with dignity and respect and are accountable to one another to
maintain a safe, productive, diverse and environmentally responsible workplace.
4.
Avoid conflicts of interest
We avoid activities or personal interests that create or appear to create a conflict of interest with
respect to our responsibilities as Cardinal Health employees.
5.
Compete responsibly in the marketplace
We compete for business diligently, openly and honestly and are
tenacious in fulfilling our commitments to customers.
6.
Protect the integrity of the global supply chain
We support initiatives and policies to help provide a secure worldwide supply chain.
7.
Interact appropriately with government entities,
officials and employees
We comply with the laws and regulations that govern the political process
and interactions with government entities, officials and employees.
8.
Maintain accurate books and records
We record information accurately so that employees, customers, suppliers, investors
and other stakeholders can trust the information and make informed decisions.
9.
Protect information and assets
We properly use and take reasonable precautions to safeguard
Cardinal Health information and physical assets.
10.
Encourage individual volunteerism and corporate social responsibility
We encourage involvement in the communities where we live and work which may include
individual voluntary participation in community service and corporate social responsibility.
Standards of Business Conduct
Business Conduct Line 800.926.0834
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www.businessconductline.com
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We work together, according to shared standards
and values, to make wise decisions that foster a
culture of trust and responsible business conduct.
We expect the same from the consultants,
contractors and other third party partners who
conduct business with us or on our behalf.
Why it matters
Our reputation as a leading healthcare company
depends on each of us making appropriate
decisions every day. By following the Standards of
Business Conduct and applicable laws, policies and
procedures, we make Cardinal Health a desirable
place to work, a trusted advisor to our customers
and an organization in which investors can place
their confidence and trust.
Act with
integrity and
in compliance
with the law
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Business Conduct Line 800.926.0834
Question and answer
Q:
I just read an article about some new local regulations that will
be effective in a few months. We will need to change some of
our global processes to comply with the new requirements in
our region. Our budget is already under pressure and the new
requirements will add more time to our process, negatively
affecting our productivity. What should I do?
A:
Complying with all legal and ethical obligations is essential to
our business goals. Sustainable long-term performance requires
that business results are achieved in a manner that complies with
applicable local laws and regulations. Bring the matter to your
manager’s attention.
Q:
What should I do if I believe an act is potentially violating our
Standards of Business Conduct or putting the Company’s
reputation at risk?
A:
It’s best to always ask questions, seek guidance and raise concerns
by starting with your manager, Legal, Compliance or reporting
anonymously through the Business Conduct Line.
What we expect of our employees
We expect employees to act with integrity and trust them to do
the right thing. The Standards of Business Conduct provides overall
guidance, but is not a substitute for reading, understanding and
following the policies and procedures that apply to your job. Your
manager is your best resource for job-specific information.
Do the right thing
•
Understand and comply with the Standards of Business
Conduct and any applicable laws and regulations, as well as
department or company policies and procedures
•
Check mycardinalhealth.net for the most up-to-date
policies and procedures
•
Participate in training opportunities
•
Ask the difficult questions and challenge each other in a
professional and respectful manner to address issues
•
Ask your manager or the Ethics and Compliance department
for clarification or direction especially if there appear to be
conflicting obligations
What we expect of our leaders
We expect our leaders to understand that business results
and acting with integrity are essential and we cannot have one
without the other. To sustain a culture where trust and responsible
business conduct are expected, our leaders must be a trusted
resource for employees.
Do the right thing
•
Lead by example; reinforce with employees that business results
are not more important than acting with integrity
•
Make employees available for and reinforce the importance of
attending training
•
Consider compliance efforts and results when evaluating and
rewarding employees
•
Make sure employees understand their responsibilities and feel
comfortable raising concerns without fear of retaliation
•
Deal immediately with business conduct issues and take
appropriate disciplinary action with the help of the Ethics and
Compliance, Legal or Human Resources departments
•
Identify compliance risks and take prompt action to
address them
www.businessconductline.com
We ask questions, seek guidance and raise concerns in
order to work together with confidence and trust.
Why it matters
Our reputation, our relationships and our future
all depend on our commitment to integrity and
compliance. When you do not know which decision is
the best, or if you suspect someone else is not acting
appropriately, the best thing you can do is to reach
out and check with the resources available to you. It is
better to ask the question than regret the action.
2
Ask questions,
seek guidance
and raise concerns
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Business Conduct Line 800.926.0834
Ethics and Compliance department
The Ethics and Compliance department, under the leadership of the
Chief Legal and Compliance Officer, is responsible for the Standards
of Business Conduct, the Business Conduct Line and partnering with
business leaders to identify, assess and address compliance risks.
•
Telephone: 614.757.7504
•
Email: Ethics and Compliance
(GMB-DUB-Ethics&Compliance@cardinalhealth.com)
•
Mail: 7000 Cardinal Place, Dublin, OH 43017, USA
•
Fax: 614.757.6948
Business Conduct Line
•
You may access the Business Conduct Line by telephone using the
numbers listed in the back of this booklet or over the Internet at
www.businessconductline.com
•
Open 24/7 and operated by an independent, third-party company
•
Multilingual agents available. There may be a brief pause while
the appropriate operator is placed on the line
•
Callers have the option to remain anonymous
•
Main telephone number: 800.926.0834
•
See list at the back for country-specific local phone numbers
No retaliation
Cardinal Health will not discharge, demote, suspend, threaten,
harass or, in any manner, retaliate against an employee based on
that employee truthfully raising a concern about any actual or
suspected misconduct or other risks to the business. If you believe
you have been retaliated against for raising a concern, immediately
contact the Ethics and Compliance department or the Business
Conduct Line.
Do the right thing
•
Don’t assume the way things have always been is appropriate
•
Ask questions, seek guidance and raise concerns
•
Talk to your manager
•
Call or email your concerns to the Ethics and Compliance
department or Business Conduct Line
A word about investigations
Cardinal Health handles inquiries and investigations confidentially.
The substance of your inquiry and your identity (if you choose to
provide your name) is disclosed on a strict need-to-know basis,
to the extent deemed necessary by Cardinal Health to conduct
a proper investigation and to respond appropriately. When you
ask a question, seek guidance or raise a concern, you will receive
a response if you have provided the company with a means to
do so. If a concern is substantiated, the situation will be resolved
through appropriate corrective actions which may include, among
other things, clarification of a company policy, additional training,
facility or process change and/or disciplinary action.
Do the right thing
•
Cooperate during investigations and audits during
your employment with Cardinal Health and after your
employment ends
•
Tell the truth
•
Respect confidentiality and do not discuss an investigation
or audit with other employees
•
Consult with the Legal department prior to altering or
destroying any records related to an investigation or audit
Accounting, auditing, internal controls or financial reporting
In addition to the Business Conduct Line, you may submit written
concerns regarding accounting, internal controls, financial
reporting or auditing matters to the Senior Vice President of Ethics
& Compliance, to the Chief Legal and Compliance Officer or to the
chairperson of the Cardinal Health Audit Committee of the Board
of Directors, c/o Chief Legal and Compliance Officer, 7000 Cardinal
Place, Dublin, OH, 43017 USA.
Question and answer
Q:
I’ve been thinking about calling the
Business Conduct Line, but I’m not sure
if I should. My manager told me to do
something that I feel is dangerous and may
violate a safety regulation. I think I should
tell someone who can look into this, but I’m
afraid that my manager will make my job
difficult for me if I do. What should I do?
A:
Even in great companies, people sometimes do things they shouldn’t. You have identified
what you believe is a potentially serious matter. If something does not seem right, you
should speak up. Your manager is often the best place to raise concerns, but because it
is your manager’s request that concerns you, calling the Business Conduct Line is a good
option. You have the option to remain anonymous.
When you call the Business Conduct Line, we will look into the situation and will not
tolerate your manager or anyone else retaliating against you. If you believe you have been
retaliated against for raising a concern, you should immediately contact the Ethics and
Compliance department or the Business Conduct Line. The right thing to do is to report
your concerns.
Other matters, including ethical, quality and legal and regulatory compliance matters
In addition to the Business Conduct Line, you may submit concerns
regarding other matters, including ethical, quality and legal and
regulatory compliance matters to the Senior Vice President of Ethics
& Compliance, to the Chief Legal and Compliance Officer or to the
chairperson of the Cardinal Health Risk Oversight Committee of
the Board of Directors c/o Chief Legal and Compliance Officer, 7000
Cardinal Place, Dublin, OH 43017 USA.
www.businessconductline.com
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www.businessconductline.com
We treat one another with dignity and respect and
are accountable to one another to maintain a safe,
productive, diverse and environmentally
responsible workplace.
Why it matters
To create and maintain a safe and productive work
environment, it’s up to all of us to respect the unique
character of every colleague, to appreciate the
diversity of thought, experiences and backgrounds
that they bring to the table and to treat each other
with courtesy, respect and professionalism. It’s equally
important to comply with environmental, health and
safety requirements and operate with all required
permits, approvals and controls.
3
Treat one another
fairly and foster a
safe, productive,
diverse and
environmentally
responsible
workplace
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Business Conduct Line 800.926.0834
Environment, health and safety
We demonstrate our commitment to the health and safety of our
employees, contractors and the community by complying with
environmental, health and safety laws and operating with required
permits, approvals and controls.
Do the right thing
•
Observe environmental, health and safety laws,
regulations and policies
•
Report accidents, injuries or unsafe practices or conditions
•
Take appropriate and timely action to correct known
unsafe conditions
Fair treatment and diversity
We provide equal opportunity to employees and applicants
during the employment process. We are committed to
building a diverse, inclusive workplace that is representative
of the communities in which we operate and that is free from
discrimination. In addition, we are dedicated to fostering a work
environment where employees are respected and enjoy coming
to work.
Do the right thing
•
Be open, honest and professional in your dealings with your
manager, your colleagues and your customers
•
Embrace the differences and unique qualities of your co-workers
and those with whom Cardinal Health does business
•
Treat others with respect and value their differences
•
Do not discriminate on the basis of any group status or
characteristic protected by law or Cardinal Health policy (e.g.,
person’s age, disability, gender, etc.)
Harassment and bullying
We do not tolerate harassment, intimidation or bullying of
employees by co-workers, managers or any other individuals with
whom employees come into contact while conducting business.
Do the right thing
•
Maintain a safe working environment that is free from bullying,
intimidation and harassment
•
Do not act in a disrespectful, hostile, intimidating, threatening, or
harassing manner
•
Report incidents
Substance abuse
The health and safety of our employees demands that each
employee report to work free from the influence of any substance
that could prevent him or her from conducting work activities
safely and effectively. Substance abuse and the misuse of alcohol
and drugs pose unacceptable risks for safe, secure and efficient
operations and will not be tolerated.
Do the right thing
•
Never use illicit or illegal drugs
•
Do not report to work while under the influence of any substance
that could prevent you from conducting work activities safely and
effectively (e.g., alcohol, medication that can make you drowsy
while operating heavy machinery, etc.)
Workplace violence prevention
We do not tolerate workplace violence and will investigate and
take appropriate action against unacceptable behavior such as
physical assaults, fights, threats, intimidation, and the intentional
or reckless destruction of company or employee property or the
property of companies with whom we do business. We reserve
the right to inspect work areas and the personal possessions of
employees and visitors.
Do the right thing
•
Maintain a safe working environment that is free from threatened
or actual physical harm
•
Do not bring or use weapons while on company business or on
company property in violation of company policy or federal, state
or local law
•
Cooperate with inspections
Q:
A co-worker has repeatedly refused to provide me with
information that is essential for my job, has called me
derogatory names and has told other employees that I am not
qualified to do my job. How should I handle the situation?
A:
Harassment and intimidation can occur in many forms. In
this situation, it appears that the employee is persistently
bullying by making demeaning comments that are intended
to erode your self-confidence or self-esteem. If you feel
comfortable doing so, ask the employee to stop. If you do not
feel comfortable doing this or if the harassment or bullying
continues, talk to your manager. If the issue is not adequately
addressed by your manager, you may also contact your Human
Resources representative or call the Business Conduct Line.
Bullying undermines the respect and trust that is central to
the way that we conduct business and is not permitted.
Q:
My manager keeps asking me out on a date and putting
his arm around my shoulder when he talks to me even
after I have told him I am not interested and to please
stop. My performance review is next month and he told
me that I have a better chance for a promotion if I go
out with him. How should I handle this situation?
A:
Sexual harassment is not tolerated by the company. It
includes unwelcome sexual advances, requests for sexual
favors and other unwelcome verbal or physical conduct of a
sexual nature. Immediately contact your Human Resources
representative or call the Business Conduct Line.
Q:
I’m new to Cardinal Health and don’t understand some of the
safety rules. I feel awkward asking questions. What should I do?
A:
We encourage employees to ask questions, especially when
safety is involved. Talk to your manager. Your manager has
the responsibility to provide you the training you need
to do your job. If you don’t feel comfortable talking with
your manager, talk with the Environment, Health and
Safety department or call the Business Conduct Line.
Question and answer
www.businessconductline.com
13
www.businessconductline.com
We avoid activities or personal interests that create
or appear to create a conflict of interest with respect
to our responsibilities as Cardinal Health employees.
Why it matters
We make decisions based on sound business
judgment and unclouded by any personal interest,
relationship pressure or potential for personal gain.
The best way to avoid a potential conflict of interest
is to ask questions and address any situation that has
the potential to be misinterpreted by others.
4
Avoid conflicts
of interest
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Business Conduct Line 800.926.0834
Conflicts of interest
A conflict of interest arises when your outside personal, financial,
political or social interests or activities have the potential of making it
difficult to perform your work in the best interest of Cardinal Health.
You must avoid situations that conflict, or could have the appearance
of conflicting, with the best interests of Cardinal Health. Conflicts of
interest can occur in a variety of ways; however, the following situations
can often produce conflicts of interest and should be carefully analyzed:
•
Doing business with family or close friends
•
Making charitable contributions on behalf of the company to a
charitable organization affiliated with or recommended by a current
or prospective customer or supplier
•
Hiring consultants, agents and other third parties with
whom you have a personal relationship
•
Investing in real estate, patent rights or businesses
of interest to Cardinal Health
•
Pursuing outside employment with a customer, vendor or supplier
•
Accepting entertainment from people or entities with whom we
do business
Do the right thing
•
Make decisions in the best interests of Cardinal Health
•
Resolve conflicts of interest in an open, transparent manner
•
Avoid competing in any way with Cardinal Health
•
Do not take for yourself opportunities that were discovered
through the use of company property, information or your
position or use company property, information or your position
for personal gain
•
Ask your manager or the Ethics and Compliance department
questions about any situation that could be perceived as a
potential conflict of interest
Restrictions on buying and selling stock and securities (insider trading)
Do not buy or sell stocks or other securities of a company while
aware of material nonpublic information about that company.
Likewise, you may not communicate material nonpublic
information, other than permitted by Cardinal Health policies,
to anyone else (for example, to relatives, friends, or co-workers)
until that information has been released publicly. Information
is material if there is a substantial likelihood that a reasonable
investor would consider it important in making an investment
decision to buy, hold or sell a security. Information is nonpublic
if it has not been publicly released by the company or is not
otherwise publicly available. These obligations continue after your
employment with Cardinal Health ends.
Do the right thing
•
Do not buy or sell stock or other securities of a company while
aware of material, non-public information about that company
•
Contact the Legal department if you have any questions about
trading in stocks and securities
Q:
I am a full-time employee of Cardinal Health. I’ve been asked to
consult with another healthcare company using the skills I use in
my job with Cardinal Health. Is that a conflict of interest?
A:
You can work a second job without a conflict of interest so long
as the second job does not interfere with your responsibilities
at Cardinal Health (e.g., you are able to continue to dedicate
necessary time and attention to your Cardinal Health job, you are
not competing with Cardinal Health, you do not use the assets or
confidential information of Cardinal Health, etc.). Since you are a full-
time employee and would be using the same skills you use in your
job with Cardinal Health, there is a potential for a conflict of interest.
The best way to avoid a conflict is to talk with your manager before
accepting any outside employment or consulting arrangement.
Q:
I know that the company is acquiring a large public company.
This deal will be material to both companies but has not yet been
announced publicly. Can I buy shares of the company we are
acquiring so long as I do not buy shares of Cardinal Health?
A:
You may not buy or sell the shares of either Cardinal Health or
the company we are acquiring until the first trading day after the
transaction has been publicly announced. Until the information is
public, you must not share this material information with anyone
unless permitted by Cardinal Health policies. For example, you
must not share this information with co-workers who do not have a
business need to know the information or with relatives or friends.
Question and answer
We compete for business diligently, openly
and honestly and are tenacious in fulfilling our
commitments to customers.
Why it matters
Competing responsibly in the marketplace builds
our long-term relationships and enhances our
reputation. It is essential that our customers and
suppliers know they can trust Cardinal Health.
5
Compete with
integrity in the
marketplace
www.businessconductline.com
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Business Conduct Line 800.926.0834
Competitive intelligence
Properly acquiring and using information about other companies,
including our customers, suppliers and competitors, is a routine
part of operating in the marketplace.
Do the right thing
•
Respect a person’s obligation to protect the confidential
information of their current and former employers
•
Question how any information about a competitor was obtained
and whether the information is confidential, especially if
circumstances are suspicious (e.g., you suspect it has been
supplied in violation of a legal or contractual commitment)
•
Do not acquire competitive intelligence through improper
or illegal means
Interactions with consultants, contractors and other business partners
We conduct business only with those consultants, contractors
and other third party business partners that are reputable and
qualified in the services to be performed (e.g., do not appear
on any government debarment or excluded parties list). We
do not do anything indirectly through third parties that would
otherwise be prohibited if we did it directly. When conducting
business for Cardinal Health, consultants, contractors and
other business partners are required to observe the same
level of responsible conduct and compliance with the law as
Cardinal Health employees.
Do the right thing
•
Follow established procedures before you enter into any
agreement with a consultant, contractor or any other third party
business partner
•
Provide consultants, contractors and any other third party
business partners with a copy of the Vendor Code of Conduct
and explain our expectations
•
Complete appropriate due diligence regarding the background
and qualifications of consultants, contractors or any other third
party business partners
Interactions with competitors (fair competition and antitrust)
Generally speaking, antitrust and competition laws constrain or
prohibit discussions or agreements among competitors that
restrain trade. This can include discussions about past, present
or future prices, bids, tenders, terms or conditions of sale and
territorial markets. In addition, any understanding or agreement
between a company and its supplier/distributor regarding the
prices the company may charge for products or limits on a
company’s geographic territory can cause antitrust concerns.
Do the right thing
•
Exercise caution when talking with a competitor
•
Be alert to improper discussions when attending trade
association functions or industry meetings
•
Refrain from discussing or entering into any agreement that
is intended to restrain trade
•
Seek guidance from the Legal department whenever you
have any questions or are unsure about a situation involving
a competitor
Interactions with customers and healthcare professionals
Our interactions with customers should focus on developing
mutually beneficial business relationships so our customers
can focus on their patients. Employees may not offer or provide
anything of value (e.g., donations, grants, scholarships, subsidies,
support, consulting contracts, gifts, etc.) to a customer in
exchange for purchasing, recommending or arranging for
the purchase of products or for a commitment to continue to
purchase products or services. If properly structured, discounts
and rebates provided to a healthcare provider on purchases of
products or services are generally permitted.
Do the right thing
•
Read and understand the policies and procedures that apply to
interactions with customers and healthcare professionals
•
Refrain from improperly offering anything of value to win
business or to influence a business decision
•
Consult with the Legal department prior to entering into
contracts with customers which provide for discounts and rebates
•
Seek guidance from the Ethics and Compliance department
whenever you have a question about interactions with customers
and healthcare professionals
Q:
What do I do if I’m in a trade association meeting with
competitors and a competitor suggests that everyone in the
group increase their pricing for an upcoming government bid
or tender?
A:
You must immediately object to the subject and end the
discussion. This may require you to leave the room if the improper
discussion continues after you object. Even after stating an
objection, failure to withdraw from the group could be used to
support an argument that an agreement existed if the improper
discussion is continued. If a record of the meeting is maintained,
you should ask that your objection (and if necessary, departure)
be noted for the record and request a copy of the record. Any
improper discussions should be promptly reported to the Ethics
and Compliance or Legal departments regardless of the steps you
took to object and document the objection.
Q:
One of my customers who is a physician has promised to increase
her business with Cardinal Health if I hire her as a consultant. She
is a good customer and might be able to help us with a new
product launch. What should I do?
A:
You may not provide anything of value to induce a customer
to purchase our products or services. This customer request is
inappropriate and may violate the law, as this physician is tying
her decision to purchase our products and services to her desire
to have a consulting agreement with Cardinal Health. We may
only engage a consultant when we have a legitimate business
need for the services. Not one purpose of a customer consulting
arrangement should be to get the customer
to purchase our products or services.
Question and answer
Marketing practices
Cardinal Health believes in competing for business diligently,
openly and honestly. Unless there is sufficient research to
substantiate a comparison between a Cardinal Health product
and a competing product, you may not use comparative
advertising of any sort, whether by written advertisement,
demonstration, comments or innuendo.
Do the right thing
•
Promise only what you can deliver and deliver on what
you promise
•
Respond to customer feedback or complaints in a courteous,
efficient and timely manner
•
Describe Cardinal Health products, services and prices truthfully
and accurately
•
Comply with Cardinal Health marketing standards and have
marketing activities appropriately reviewed before launch
•
Do not disparage or make false statements about
our competitors and their business practices
Purchasing practices
Cardinal Health bases purchasing decisions on achieving optimal
value for the company and alignment to our business standards
and goals. We treat fairly and do not discriminate against
suppliers; however, it is appropriate to differentiate among
suppliers based upon appropriate business considerations.
Cardinal Health expects suppliers to comply with applicable laws
and to conduct business with integrity.
Do the right thing
•
Read and understand the policies and procedures that apply to
interactions with suppliers
•
Do not provide a commission that is disproportionate to the
services provided
•
Do not request or accept any kind of personal payment or benefit
or other improper advantage
www.businessconductline.com
18
www.businessconductline.com
We support initiatives and policies to help provide a
secure worldwide supply chain.
Why it matters
We provide products and services that have the
potential to save, or if misused, to harm lives. It’s
essential that at every step of the process our
employees handle these products in compliance
with applicable local regulations and standards, so
that hospitals, pharmacists, doctors and patients can
rely on us to provide quality healthcare products.
6
Protect the
integrity of
the global
supply chain
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20
Business Conduct Line 800.926.0834
Quality
We have quality systems in place to ensure that we manufacture,
handle, store and distribute products in accordance with
applicable legal and regulatory requirements. Every employee is
responsible for following our quality processes when working with
the products we sell.
Do the right thing
•
Do not compromise quality for deadlines
•
Understand and comply with the policies that cover
the manufacture, storage, handling and distribution of
products we sell
•
Respond promptly to quality issues you observe or that are
raised by customers or vendors by talking to your manager
or the Quality and Regulatory Affairs department
Anti-diversion compliance
Cardinal Health is committed to maintaining the integrity of the
supply chain by developing and maintaining processes to help
guard against diversion. We maintain “know your customer”
policies and procedures to validate that products we ship are
sold in accordance with legal and contract requirements and are
received by customers for their legitimate use.
Do the right thing
•
Know our customers in order to determine whether they and
their purchases meet our standards
•
Purchase from suppliers that meet our quality, delivery,
service and pricing standards and that are responsible
corporate citizens
•
Be alert for any warning signs of supply chain integrity issues
with a particular supplier or customer
•
Promptly raise concerns about supply chain integrity,
including potential diversion, to your manager or the Quality
and Regulatory Affairs department
Trade regulations
Cardinal Health must comply with applicable U.S. and local import
and export control laws, local standards, and other procurement
standards as products move across country boundaries. Each
Cardinal Health employee is responsible to ensure that their
actions comply with the controls put in place to protect our
customers, our business partners, our employees and ultimately
Cardinal Health. Trade requirements and other local standards
apply in many aspects of our business, i.e., Manufacturing,
Sourcing, Samples, Research and Development, Service and
Repair, Supply Planning, Customer Service, International Sales,
Warehouse, Finance, Quality and Regulatory.
Export control laws and contractual agreements with our
suppliers place restrictions on how we can move products across
country boundaries and may prohibit us from doing business
with certain countries, companies or individuals. As a company
headquartered in the U.S., all employees, agents and subsidiaries
(even if located in another country) must comply with U.S. and
local trade laws.
Do the right thing
•
Understand company policy, procedure and requirements
that may apply to your transaction
•
Know your customers and business partners and the
delivery routing to prevent unauthorized diversion of goods
•
Maintain appropriate import, export and custom records
and controls
•
Ensure Global Trade department involvement prior to
proceeding with any international transaction to confirm
compliance with regulations
Money laundering and terrorist financing
Employees, especially those employees who handle cash, must
actively guard against the use of our products and services for
purposes of money laundering, financing of terrorism or other
criminal activity. Money laundering is the process by which
individuals or organizations try to make the source of funds look
legitimate by concealing the true origin of the funds. Terrorist
financing tries to conceal the destination and use of funds that may
have either legitimate or criminal origin.
Do the right thing
•
Watch out for irregularities in the way payments are
made, including:
-
Payments made by someone who is not a party to the
contract or in currencies other than the currency specified
in the documents
-
Requests to make payments in cash or cash equivalents
(e.g., traveler’s checks, money orders) or in an amount
greater than is owed
•
Report any suspicious transactions to your manager or the
Legal department
Q:
While receiving product at a distribution center, I noticed that
some refrigerated product was on the dock and no one seemed
to be working with the product. Should I raise a concern to the
dock supervisor?
A:
Yes. Refrigerated product must be promptly moved from
the dock to refrigerated storage locations. You should
immediately bring this, or any other questions or concerns,
to the attention of the dock supervisor or your manager.
Q:
While helping a new customer set-up their pharmacy, I noticed
seven customers arriving at the same time to obtain prescriptions.
I overheard the customers talking to the pharmacist and each
other about how long a drive they have ahead of them to get
home — several hours and many states away. I also noticed
that the customers appeared to be receiving powerful pain
medications. It seemed suspicious to me. What should I do?
A:
These are warning signs that indicate diversion
of controlled substances. Report what you saw to
your manager or the Business Conduct Line.
Question and answer
www.businessconductline.com
21
We comply with the laws and regulations that
govern the political process and interactions with
government entities, officials and employees.
Why it matters
Working with government entities, officials and
employees (including locally-, state- and federally-
owned hospitals) and complying with the numerous
complex regulations governing the healthcare
industry are routine business operations for many of
us at Cardinal Health. It is important that we obtain
business with government entities through bona
fide, transparent means. It is important for us to
share our experiences and insights, in an appropriate
manner, on matters of public policy and regulations
that may affect how we conduct business and assist
our customers in delivering efficient and effective
patient care.
7
Interact
appropriately
with government
entities, officials
and employees
www.businessconductline.com
22
Audits and investigations
Effectively working with regulators as they establish regulations
and conduct audits and inspections is critical to our business
operations. Contact the Legal department if you receive a request for
information from a government agency, or if representatives
from law enforcement or any government agency makes an
unscheduled, non-routine visit.
Do the right thing
•
Treat regulators professionally, with courtesy and respect
•
Provide information accurately and truthfully
•
Do not ignore requests for information, subpoenas or any other
request from the government. Contact the Legal department
•
Work with the Legal department to provide information to
regulators or law enforcement authorities
Interactions with government-related customers
There are stringent laws and regulations that apply to our
interactions with government-related customers and other
organizations. Many government-related customers have
conflicts of interest rules or similar policies which restrict or
prohibit accepting anything of value (including meals and gifts)
from vendors.
Do the right thing
•
Report to your manager or the Business Conduct Line any
concerns in connection with the award, performance or
closeout of a government contract
•
Contact the Ethics and Compliance department before you
provide anything of value to a government employee or if
you have any questions about transactions with government
organizations, institutions funded by a government agency or
individuals who work for a government entity or organization
23
Business Conduct Line 800.926.0834
Bribery and corruption prevention
Many countries in which we do business prohibit giving
someone something of value to obtain an improper advantage.
For example, under the U.S. Foreign Corrupt Practices Act,
it is a crime to bribe foreign government officials. In many
countries, the employees of hospitals, clinics and pharmacies
are government employees. In addition, we may be held
responsible for the actions of our consultants, agents or
distributors if they violate the law.
Do the right thing
•
Know with whom you are doing business — follow our due
diligence procedures and use available resources to verify
information you receive
•
Do not offer or give anything of value (e.g., gifts, cash, etc.) to,
or otherwise attempt to, obtain any improper advantage from
government officials or others with decision-making power or
influence over any aspect of our business
•
Accurately reflect all financial transactions in our books, records
and accounts
•
Follow Cardinal Health procedures for contracting, due diligence
and training before hiring a consultant, agent, distributor or any
other party to perform services for Cardinal Health outside of the
United States
Q:
A hospital customer has asked me to accompany him/her to
a meeting with a state legislator. Because I am not attending
specifically for Cardinal Health, do I need to inform anyone?
A:
Yes. It is very likely the customer asked you to join him/her
because you are from Cardinal Health and the customer wants
to leverage our size and position in the state to help with a
particular issue. Cardinal Health is very active in many states
and it is necessary to contact the Government Relations team
to discuss the specific policy issue, whether Cardinal Health is
currently working with that person and whether the state has
requirements for reporting lobbying activity. The Government
Relations team should be contacted prior to any visit.
Q:
The pharmacist at a government-owned hospital wants
to conduct our business meeting at a local restaurant. In
the past we have always split the cost, but this time he is
insisting I pay for his meal as well. What should I do?
A:
Government employees, even pharmacists employed by
state-owned hospitals, are subject to stricter rules than most
of our other customers. You should not provide meals, gifts,
any form of entertainment, travel provisions or other items of
value to any customer (e.g., employee of a government-owned
hospital, etc.) unless Cardinal Health policy, the policy of the
customer’s organization or entity and applicable laws allow it.
Question and answer
Interactions with elected officials/political contributions and lobbying
We are committed to complying with applicable federal, state
and local laws and regulations, including the U.S. Honest
Leadership and Open Government Act which places particularly
stringent restrictions on interactions with members of the
U.S. Congress. In addition, most countries, including the
United States, have very stringent rules regarding political
contributions and lobbying by companies.
Do the right thing
•
Obtain prior approval from Government Relations before:
-
Lobbying or meeting with a government official, individually
or as a part of a group (e.g., trade association, customer
visit, etc.)
-
Engaging a lobbyist at either the state or federal level
-
Inviting a state or federal legislator to a Cardinal Health facility
•
Obtain prior approval before providing meals, gifts, any form of
entertainment, travel or other item of value to a U.S. federal or
state representative or his or her staff
•
Notify your manager if you are seeking an elected office or want
to accept an appointive office and explain how the duties of the
office may affect your job performance
•
Do not use Cardinal Health resources to support your choice of
political parties, causes, political action committees
or candidates
•
Always make clear that your political views, actions and
contributions are your own and not necessarily those of
Cardinal Health
•
Report to Government Relations any contribution requested
by a U.S. federal representative, senator or member of his or
her staff
www.businessconductline.com
24
www.businessconductline.com
We record information accurately so that
employees, customers, suppliers, investors and other
stakeholders can trust the information and make
informed decisions.
Why it matters
Employees make decisions every day based on
the information recorded by other employees.
Our customers, suppliers, investors and other
stakeholders also rely on the information that we
provide to them. In addition, business documents
and communications may become public through
litigation, government investigations and the media.
As such, it is important that information is recorded
accurately and not in a misleading fashion.
8
Maintain
accurate books
and records
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26
Business Conduct Line 800.926.0834
Books and records
Employees who create or maintain reports, records or any
other information must take care to review the accuracy of
that information and not create a false or misleading report.
Particular diligence is needed when working with:
•
Documents filed with or submitted to governments or
regulatory agencies
•
Expense reports
•
Financial statements and related accounting entries
and adjustments
•
Production and quality records
•
Time reports
Do the right thing
•
While the technical requirements of financial reporting and
other legal requirements provide the baseline guidance for
what we must do, we should always strive to fully, fairly and
accurately record the facts and substance of a transaction in
reasonable detail to support the business needs as well as the
financial reporting requirements of the company
•
Do not enter into any transaction or agreement that improperly
accelerates, postpones or otherwise manipulates the accurate
and timely recording of business revenue or expenses
•
Do not make a payment or establish an account on behalf of
Cardinal Health with the understanding that any part of the
payment or account is to be used for a purpose other than as
described by the supporting documents
•
Do not participate in any transaction where you have a
reason to believe the other party intends to engage in
improper accounting
•
Correct any record that you receive that is not accurate and
truthful - contact the Legal department if you have any
questions about how to do so
Communication
Before sending, posting, emailing, discussing or otherwise
allowing the content of any document to be seen, be sure your
message is clear and concise and not ambiguous. Cardinal Health
prepares all public communications and disclosures in reports
and documents we file with or submit to regulatory agencies in
a full, fair, accurate, timely and understandable manner and in
accordance with applicable legal standards for such filings
and submissions.
Do the right thing
•
In all communications, take care to avoid false, misleading
or derogatory remarks or characterizations of people, the
company or other companies, as well as the use of exaggeration,
guesswork or legal conclusions
•
Remember that email, voicemail and other forms of electronic
communication may be a business record
Authority to act on behalf of Cardinal Health
Our customers, suppliers and the public must be able to trust that
the person they are dealing with is authorized to act on behalf of
the company.
Do the right thing
•
Understand and adhere to the limits of your authority to act on
behalf of Cardinal Health
•
Sign only those documents, including contracts, that you are
authorized to sign and that you believe are accurate and truthful
•
Refer all requests from investors or analysts to the Investor
Relations department and all media requests to the Public
Relations department
Q:
Our department is under pressure to meet the quarterly earnings
projections. I think my manager reported inaccurate numbers last
quarter to meet the projections thinking we could make it up this
quarter. What should I do?
A:
It’s never acceptable to report earnings that are not accurate.
The company requires accuracy of all of our books and records.
You should report questionable entries immediately to the
Ethics and Compliance department or the Audit Committee of
the Board of Directors or through the Business Conduct Line.
Q:
I have $25,000 in financial approval authority. I need to
have a $75,000 invoice from a major, long-time vendor paid
immediately. My manager has approved these invoices in
the past, but my manager is out of town. Is it all right for
me to split the invoice into three separate invoices?
A:
No, employees may not split invoices or expenses to avoid
exceeding approval limitations. You must wait until your manager
returns or find someone else with sufficient approval authority
and knowledge of the transaction to approve the invoices.
Question and answer
www.businessconductline.com
27
www.businessconductline.com
We properly use and take reasonable precautions
to safeguard Cardinal Health information and
physical assets.
Why it matters
Information created, obtained or compiled by or on
behalf of Cardinal Health belongs to the company.
Such information and the physical assets of Cardinal
Health are critical to the continuing success and
operation of the company and must be protected.
We expect employees to respect and safeguard the
company assets they use, including information,
computers, personal electronic devices, furniture,
buildings and vehicles.
9
Protect
information
and assets
28
29
Business Conduct Line 800.926.0834
Confidential information
You may not disclose Cardinal Health confidential information (e.g.,
customer lists, directories, files, reference materials and reports,
computer software, data processing systems, computer programs,
databases, etc.) to anyone outside the company unless: (1) a proper
confidential disclosure agreement has been entered into; or (2)
the disclosure has been properly authorized by Cardinal Health
management and the Legal department. To protect confidential
information, the use of audio and visual recording devices on
company property, including cellular telephone cameras, is not
permitted without prior approval of management.
Do the right thing
•
Protect Cardinal Health confidential information and use it
only for valid business purposes during your employment with
Cardinal Health and after it ends
•
Protect confidential information that other companies or
individuals have entrusted to Cardinal Health during your
employment with Cardinal Health and after it ends
•
Properly label information to indicate how it should be handled,
distributed and destroyed
•
Do not disclose confidential information or intellectual
property, including posting on any forms of social media, or
discussing in public places
•
Report if you know or suspect that confidential information has
been lost and/or seen by unauthorized individuals
•
Follow Cardinal Health procedures for reuse, redeployment
and return of work equipment during your employment with
Cardinal Health and after it ends
•
Do not use assets in a manner that might lead to loss or
damage, including uses that might introduce viruses or cause a
breach of our information technology security
•
Ask your manager for guidance if you are concerned about the
appropriateness of responding to requests for information
Personal use
You are permitted to occasionally use the company’s computer
and telephone systems for personal purposes that are consistent
with the company policies and Standards of Business Conduct, do
not interfere with the performance of your responsibilities with
Cardinal Health and are not otherwise contrary to the interests
of Cardinal Health. Keep in mind that such use must be nominal
in terms of time. Under no circumstances may you use company
assets in any manner that is contrary to Cardinal Health policy
or connected with offensive, sexually explicit or inappropriate
material, including using your company-provided computer to
view or send such material during or after normal working hours.
Do the right thing
•
Keep personal use of company assets to a minimum
•
Understand that personal messages on Cardinal Health
computer and telephone systems may be monitored and you
should not have any expectation of privacy
•
Do not give the impression that you are speaking on behalf of
Cardinal Health or misrepresent or disparage Cardinal Health
in any personal communication, including any forms of social
media, regardless of whether the communication occurs via a
Cardinal Health asset
•
Do not use company assets or information in connection
with any activity or employment other than your role at
Cardinal Health
Personal information
Cardinal Health is committed to complying with the laws that govern
the collection, use and management of personal information in the
countries where we do business. Specific laws in many countries
govern how employees handle personal information, prescription
information or other patient-identifiable healthcare information.
Do the right thing
•
Protect the personal information of current and former
employees, directors, suppliers, customers, job applicants,
patients, etc.
•
Collect, use, maintain or share personal information in
compliance with Cardinal Health policy and applicable law
•
Report any concern that personal information might not be
properly protected or the protections have been compromised
Intellectual property
Intellectual property (e.g., innovations, discoveries, ideas, etc.) is
critical to the continuing success and operation of the company and
must be protected as confidential and proprietary information. The
unauthorized disclosure of intellectual property may jeopardize its
legal protection. Employee contributions to intellectual property
are the property of Cardinal Health. Employees agree that any and
all rights to intellectual property (whether or not protected by
patent, copyright, trademark or trade secret) are the property of
Cardinal Health.
Do the right thing
•
Promptly disclose to the Legal department any intellectual
property you create through your employment
•
Execute and process any applications, assignments or other
documents that Cardinal Health deems necessary or advisable
to obtain or protect our intellectual property during your
employment with Cardinal Health and after it ends
•
Do not use the company logo without permission
Records management
Numerous laws require certain documents to be kept for various
periods of time. You must identify, maintain, safeguard and dispose
of records in the normal course of business in compliance with the
current records retention schedule and any document preservation
notice you may receive from the Legal department. Under no
circumstances may you or anyone under your direction selectively
edit or discard records.
Do the right thing
•
Retain, protect and dispose of records according to company policy
•
Contact the Legal department immediately if you learn of a
subpoena or pending, imminent or contemplated litigation or
government investigation
-
Retain and preserve records that may be responsive to the
subpoena, are relevant to the litigation or that may pertain to
the investigation until the Legal department advises you how
to proceed
-
Take steps to preserve from destruction all relevant records
(such as electronic and voice-mail messages) that without
intervention would automatically be disposed of (destroyed or
erased) according to the records retention schedule
www.businessconductline.com
30
Q:
What are some examples of Cardinal Health confidential or
proprietary information and how must I protect it?
A:
A good rule of thumb is that any information that has not been
released to the public is confidential information and should
not be discussed with anyone who does not have a legitimate
business need to know it. Specific care should be given to
confidential information that could put the company at a
competitive disadvantage if it was disclosed (e.g., trade secrets,
customer/patient/employee information, financial
data, business plans, etc.)
The following are a few examples of how to protect
confidential information:
•
Put confidential information in a locked drawer before leaving
the office
•
Password protect or encrypt the data
•
Store employee data in a fireproof, locked cabinet or
electronically on an encrypted computer
Q:
A customer emailed me a file containing patient data for
Cardinal Health to analyze. After the analysis is complete, is it
acceptable to email the patient data and the analysis back to
the customer?
A:
Yes but due to the sensitive nature of patient data and legal
requirements regarding privacy, you may do so only if the
file containing the patient data and the analysis is encrypted.
Contact the Ethics and Compliance department with
any questions.
Question and answer
Business Conduct Line 800.926.0834
31
www.businessconductline.com
We encourage involvement in the communities
where we live and work which may include
individual voluntary participation in community
service and corporate social responsibility.
Why it matters
Cardinal Health is committed to being a responsible
citizen in the communities and countries where
we are located and encourages employees to
share their time, talent, knowledge and skills
with charitable organizations. The Cardinal
Health Foundation encourages volunteerism and
community service with resources and support.
We also strive to minimize our impact on the
environment by requiring that every facility has an
environmental, health and safety plan in place and
by supporting waste reduction and recycling efforts
at our facilities and in our communities.
10
Encourage
individual
volunteerism and
corporate social
responsibility
32
33
Business Conduct Line 800.926.0834
Q:
My team would like to support a local charity by helping them at
their annual marathon. We would register participants, hand out
water to the runners, etc. Does the Cardinal Health Foundation
provide financial support for group volunteerism?
A
: Yes. The Cardinal Health Foundation provides financial
support, in the form of team building and team fundraising
grants, to local charities when a group of employees volunteer
to help the charity with an event like you described. The
Foundation also provides leadership grants for employees
who are board members of non-profit organizations. Contact
Community Relations to make sure your event qualifies.
Q:
Our business unit would like to donate some products overseas
to a country recently devastated by a hurricane. Can we do that?
A:
We typically work through established international
organizations in order to comply with regulatory and legal
requirements. In general, we do not donate pharmaceuticals
but may donate other products. Contact Community
Relations for prior approval of any donations.
Question and answer
Individual volunteerism
You are encouraged to let others know about your volunteer
activities; however, always make clear that your views, actions
and contributions to charitable organizations are your own and
not necessarily those of Cardinal Health. In addition, when asking
other employees to support a cause or join in a charitable event,
take care not to pressure them to contribute to or join your
preferred charitable or political causes. You may not use Cardinal
Health resources or assets to support your choice of causes, unless
permitted by company policy or procedure.
Do the right thing
•
Learn more about the Cardinal Health Foundation and its
contribution to our communities
•
Talk to the Community Relations department about
opportunities for volunteer leadership positions
Corporate social responsibility
Cardinal Health strives for a higher standard of business
operation by supporting corporate social responsibility,
including environmental stewardship. Part of the Cardinal Health
commitment to the environment depends on employees acting
in support of our environmental, health and safety practices and
initiatives. While business segments have designated employees
who coordinate and manage these programs for the company, all
employees are responsible for environmental, health and safety
performance. Each facility must have an environmental, health
and safety plan in place that it follows and updates each year.
Do the right thing
•
Minimize, to the extent practical, the adverse impact
Cardinal Health products, processes and services have
on the environment
•
Reduce the use of energy, water and other resources
where feasible
•
Support waste reduction and recycling efforts at
Cardinal Health and in your community
Resource list
Resource
Contact information
Scope
Your manager
Ask questions, raise issues, seek guidance or raise concerns
Community Relations
communityrelations@
cardinalhealth.com
Non-profit contributions, volunteerism and
community involvement
Ethics and Compliance
614.757.7504 (telephone)
614.757.6948 (fax)
GMB-DUB-EthicsandCompliance@
cardinalhealth.com
7000 Cardinal Place
Dublin, OH 43017
USA
Ask questions, raise issues, seek guidance or raise concerns about any
issue, including Standards of Business Conduct and companywide
corporate policies, questions regarding gifts and entertainment,
bribery and corruption prevention, fair competition, antitrust,
healthcare fraud and abuse, interactions with customers and
healthcare professionals and any other ethics or compliance concerns
Global Environment,
Health and Safety
GMB-DUB-EHS-Corp@
cardinalhealth.com
Environmental, health and safety matters, including compliance
programs and management systems
Global Security
888.880.7642 or
614.757.3333
GMB-DUB-SOIC@cardinalhealth.com
Security issues regarding people, property, products or information
and drug testing policies and procedures
Global Trade
614.757.5033
Import, export and boycott issues
Government Relations
GMB-Government-Relations@
cardinalhealth.com
Political activity and contribution issues
Human Resources
1.866.HR1STOP
(1.866.471.7867)
HR transactions (e.g. payroll, benefits, leave of absence) for employees
in the U.S. and Canada. All other employees consult local HR
Investor Relations
614.757.4757
Shareholder or analyst inquiries or issues
Legal
614.757.6421
LRC-Operations@cardinalhealth.com
Interpretation of local laws, questions regarding gifts and
entertainment, bribery and corruption prevention, fair competition,
trading in stock, antitrust, healthcare fraud and abuse, interactions
with customers, record management, intellectual property,
consultants, agents or any other legal issue, concern or question
Public Relations
media.relations@cardinalhealth.com
Media inquiries or issues
Quality and Regulatory Affairs
614.757.6175 (Medical)
614.757.7544 (Pharmaceutical)
Quality issues or concerns with the manufacturing, handling, storage
and distribution of products
Risk Oversight Committee of
the Board of Directors
Chair of the Risk Oversight Committee
of the Board of Directors, c/o Chief
Legal and Compliance Officer, 7000
Cardinal Place, Dublin, OH, 43017 USA
Written concerns regarding other matters, including ethical, quality
and legal and regulatory compliance matters
Audit Committee of the
Board of Directors
Chair of the Audit Committee of the
Board of Directors, c/o Chief Legal
and Compliance Officer, 7000 Cardinal
Place, Dublin, OH, 43017 USA
Written concerns regarding accounting, internal accounting controls,
financial reporting auditing or other ethical matters
Business Conduct Line
Contact the Business Conduct Line through the Internet at
www.businessconductline.com
or by telephone at the toll-free numbers listed below.
Country
Telephone number
Australia
180 051 4989
Austria
0800 01 7974
Belgium
0800 72 493
Brazil
0800 000 0539
Canada
800.926.0834
Chile
80091 4420
China
400 120 0435
Colombia
01-800518 5201
Costa Rica
800-032-0088
France
0 800 90 06 37
Germany
0800 182 2841
India
000 800 050 3001
Ireland
180 033 4400
Italy
80 003 5867
Japan
0800 300 7844
South Korea
080 880 0164
Lebanon
844 597 9870
Country
Telephone number
Malta
8006 2116
Mexico
8006811814
Philippines
1800 1 322 0484
Spain
9 00876236
Sweden
020 043 99 33
Switzerland
0800 121 173
Thailand
180 001 4778
United Arab Emirates
800 032 1267
United Kingdom & Northern Ireland
0800 102 6405
United States
800.926.0834
Singapore
800 492 2637
Malaysia
1-800-81-6137
Luxembourg
800 28 507
New Zealand
0800 453 957
Netherlands
0800 0233062
Dominican Republic
1 849-200-1239
All other countires
470.219.6726
www.businessconductline.com
34
Cardinal Health
Ethics and Compliance
7000 Cardinal Place
Dublin, Ohio 43017
800.926.0834
© 2023 Cardinal Health. All Rights Reserved. CARDINAL HEALTH and the Cardinal Health LOGO are
trademarks of Cardinal Health and may be registered in the US and/or in other countries. All other
trademarks are the property of their respective owners. Patent cardinalhealth.com/patents.
Lit. No. 5EC23-2303253 (03/2023)
This booklet does not create a contract of employment between
Cardinal Health and any Cardinal Health employee, nor does it
alter the at-will employment relationship or any employment
contract and/or agreement between Cardinal Health and any
Cardinal Health employee. In addition, this booklet does not
create an implied or expressed promise for specific treatment
in a specific situation. The current edition of the Standards
of Business Conduct is posted on the Internet and intranet.
Company wide policies and procedures described in this booklet
are posted on the intranet. The Standards of Business Conduct
and Cardinal Health policies and procedures may be amended
from time to time and all amendments are effective immediately
upon posting.
It is the responsibility of each employee to review the Standards
of Business Conduct and Cardinal Health policies and procedures
from time to time to ensure that he or she is in compliance.