The BD Code of Conduct

Bringing our values to life

Revised and reinstated January 25, 2021
Message from our Chairman,
CEO, and President
We work in the most dynamic and consequential industry in the world. The products we
make today are a vital part of the global healthcare system, and we have the capability to
change even more lives in the future as we work together to fulfill our Purpose of advancing
the world of healthTM.

Our Purpose comes with enormous responsibility, and how we deliver on this promise is just
as important as what we ultimately accomplish. The answer can be found in The BD WAY—
the values, mindset, and leadership commitments that surround our Purpose—and in one
value in particular: “We do what is right.” This is the foundation of our Code of Conduct,
which guides every decision we make, every action we take, and every interaction we
have—with our customers, our business partners, our communities, and each other. This
includes speaking up when we have concerns and seeking help when we have questions.

Our Code of Conduct provides direction on how we must behave in any scenario, and it
applies to all of us, equally. Nothing is more essential to our success than doing the right
thing; by familiarizing yourself with the Code of Conduct, you’ll be taking an important step
in helping us fulfill our Purpose and potential the right way—The BD WAY.

Tom Polen
Chairman, CEO, and President

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A history of values
In 1897, Maxwell W. Becton and Fairleigh S. Dickinson founded
Becton, Dickinson and Company.

Since its founding over 120 years ago, BD has earned its
reputation for reliability and honesty. Our customers trust our
products and technologies to improve patient lives.

Our Code of Conduct helps shape our long-standing reputation so

that we can continue advancing the world of healthTM for everyone
who depends on us.

Our founders, Maxwell W. Becton and Fairleigh S. Dickinson

East Rutherford, New Jersey (1906), the company’s first plant and corporate headquarters

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 Our customers and Our company
Contents The BD WAY Doing what is right Our people marketplace and shareholders Our world Index Speak up

Table of contents
Message from our Chairman, CEO, and Our company and
President . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Our people . . . . . . . . . . . . . . . . . 16
shareholders . . . . . . . . . . . . . . . 43
A history of values . . . . . . . . . . . . . . . . . . . . 3 Fostering a respectful workplace . . . . . . 17 Avoiding conflicts of interest . . . . . . . . . . 44
Table of contents . . . . . . . . . . . . . . . . . . . . . 4 Upholding labor and Preventing insider trading . . . . . . . . . . . . 47
employment laws . . . . . . . . . . . . . . . . . . . . 20
Protecting personal data. . . . . . . . . . . . . . 49
Keeping workplaces safe and healthy . . 21
The BD WAY. . . . . . . . . . . . . . . . . 5 Protecting our assets . . . . . . . . . . . . . . . . . 52
Safeguarding confidential information
Our Purpose . . . . . . . . . . . . . . . . . . . . . . . . . . 6 and intellectual property . . . . . . . . . . . . . 54
Our customers and
Our values: Our standards of behavior . . . 6 marketplace. . . . . . . . . . . . . . . . 23 Maintaining accurate records and
Playing fair. . . . . . . . . . . . . . . . . . . . . . . . . . . 24 accounts . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56
Doing what is right. . . . . . . . . . . 7 Dealing ethically with HCPs, Safeguarding our reputation . . . . . . . . . . 58
HCOs, and government officials . . . . . . . 26
Our Code . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Making ethical decisions . . . . . . . . . . . . . . 8 Following product rules . . . . . . . . . . . . . . . 31 Our world . . . . . . . . . . . . . . . . . . . 60
Speaking up . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Scientific exchange. . . . . . . . . . . . . . . . . . . 33 Contributing to our communities . . . . . . 61
Active listening . . . . . . . . . . . . . . . . . . . . . . . 11 Ensuring product safety and quality . . . 35 Respecting human rights . . . . . . . . . . . . . 63
Zero tolerance for retaliation . . . . . . . . . . 12 Promoting products honestly. . . . . . . . . . 37 Protecting the environment . . . . . . . . . . . 64
Reporting concerns . . . . . . . . . . . . . . . . . . . 13 Dealing ethically with third parties. . . . . 39 Participating in the political process . . . 65
Being an ethical leader . . . . . . . . . . . . . . . 14 Following international trade laws. . . . . 40
Applying our Code . . . . . . . . . . . . . . . . . . . 15 Conclusion . . . . . . . . . . . . . . . . . . 66

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Our Purpose. . . . . . . . . . . . . . . . . . . . . . 6
Our values : Our standards of
behavior . . . . . . . . . . . . . . . . . . . . . . . . . 6

The BD WAY

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The BD WAY Our Purpose

The BD WAY embodies who we are, what we stand for, and why we exist. Advancing the world of healthTM
It reflects the behaviors we’re all expected to demonstrate every day, no
Our Purpose—advancing the world of healthTM —is the basis for all that
matter what we do.
we do. It motivates us and drives the decisions we make every day,
because we know our work means something.

Our values: Our standards

of behavior
We do what is right.

We thrive on innovation and demand quality.

We are all accountable.

We learn and improve every day.

We help each other be great.

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Our Code. . . . . . . . . . . . . . . . . . . . . . . . . 8
Making ethical decisions. . . . . . . . . . 8
Speaking up. . . . . . . . . . . . . . . . . . . . . . 9
Active listening. . . . . . . . . . . . . . . . . . . 11
Zero tolerance for retaliation . . . . . 12
Reporting concerns. . . . . . . . . . . . . . 13
Being an ethical leader. . . . . . . . . . . 14
Applying our Code. . . . . . . . . . . . . . . 15

Doing what
Our Purpose and values guide everything we do, but they
won’t answer every question that comes up in our work.
That’s where the Code of Conduct (the “Code”) can help.

is right
The Code explains how the principles embodied in our Purpose and
our values come to life. It helps us make the right decisions in
everything we do.

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Our Code Making ethical decisions

Our Code sets the foundation for how we behave at BD. Our value “We Many times, the right path is clear. Sometimes, however, it may be difficult
do what is right” is the cornerstone of our Code. To do what is right, we to see which way is best. When that happens, follow the steps in the
follow the laws, rules, and company policies that apply to us. We also Ethical Decision Tree, while remembering our values and our Code.
follow the highest ethical standards, even when there’s no specific law or Making decisions based on our values strengthens our ethical culture,
policy. Our Code provides guidance and resources to help us follow minimizes risk, and helps protect our company’s reputation. And don’t worry,
through on these ethical standards and protect our reputation. whenever you need advice, you can always ask your manager, Human
Resources, Internal Audit, the Law Group, or Ethics & Compliance.

Is it legal?
Unsure? Yes No

Is it in line with the BD Code of Conduct and

BD policies and procedures?

Unsure? Yes No

Ask for help Is it in line with BD’s ethical standards Do not proceed
from your manager, and culture?
There may be serious
Human Resources, the Yes consequences for BD
Law Group, or Ethics & Unsure? No
Compliance
Would I be proud of the decision if the ones
I love and respect knew about it?
Yes
Unsure? No

Would I want to read about it in

tomorrow’s news?
Yes
Unsure? No

Proceed

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 Our customers and Our company
Contents The BD WAY Doing
Doingwhat is right
what is right Our people marketplace and shareholders Our world Index Speak up

Speaking up BD associates are encouraged to have open communications with their

manager(s), local AccessHR, and HR partners. This lets all of us raise
Ask questions. Raise concerns. Seek guidance.
issues, ask questions, and constructively challenge others to be better and
We encourage and expect everyone at BD to speak up by asking questions, advance health in the process. If you’re worried about raising an issue
raising concerns, seeking guidance, and reporting actual or suspected locally, you can always contact the Ethics Office directly, and depending on
violations of laws, our Code of Conduct, our policies, relevant industry local laws, you can often do that without sharing your name.
codes, or our high ethical standards. This expectation extends to all
You may ask questions, raise concerns, or seek guidance in a
associates, vendors, and other third parties working on our behalf.
number of ways, such as:
It’s critical that we speak up when we see something that conflicts with
our values or our Code. Speaking up helps all of us protect the company’s
Using the online reporting tool at: www.bd.ethicspoint.com
reputation, and makes BD a better place to work. If there is a mistake,
we’re transparent about it, and we do what we can to make it right, to
the best of our ability. Calling the Ethics Helpline—you can find the right local or international
number on Maxwell, our intranet site

Emailing the Ethics Office: [email protected]

Ethics Helpline
Talking to your manager or a neutral and uninvolved manager
The Ethics Helpline is available anywhere in the world 24 hours a if you’d prefer
day, 7 days a week. An independent company operates the Helpline
and can take calls in most languages.
Contacting a representative in Ethics & Compliance, Human Resources,
AccessHR, Law Group, or Internal Audit
We encourage you to report issues face-to-face or by phone. You
may remain anonymous if you choose, except in the rare cases
Accessing the ethics@work app on your mobile device to connect with
when local law prohibits it. Keep in mind that it may be more
Ethics & Compliance resources anywhere, anytime
difficult to investigate and address your concerns if you remain
anonymous. For more information and examples of the types of issues to report,
see the Global Speaking Up Policy.

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Speak up

Speaking up (continued)

Advancing your knowledge

Speaking up: Myths versus facts
We understand that some people will have questions about whether
they should report possible misconduct. Here are some common
myths about the Ethics Office and speaking up, along with the facts
that counteract those myths.

Myth #1: BD will retaliate against me for speaking up.

Fact: BD does not tolerate any form of retaliation against anyone
who reports an issue.

Myth #2: Nothing will happen as a result of my report.

Fact: BD takes all reports seriously and will conduct a prompt, fair,
and thorough investigation. See Reporting concerns.

Myth #3: It’s not right to “tell” on a co-worker.

Fact: Speaking up is not always easy, but it is always the right thing
to do. It helps us protect BD, our colleagues, and ourselves from
further harm. It is also something that is required of each of us as
associates.

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Active listening
Authentic conversations go two ways. When both people are fully
engaged in a conversation, they will each understand what the other is
saying. That kind of good communication is important if we want to
make sure we’re always doing the right thing. So, in addition to speaking
up, we expect all BD associates to use active listening to fully appreciate
what someone is saying.
An active listener does five things:
• Fully concentrates on the speaker
• Asks clarifying questions while confirming understanding
• Replies based on what is said, not just the listener’s point-of-view
• Affirms the genuineness of the speaker’s feelings, perceptions,
and conclusions
• Recalls what the speaker said
Active listening will help you bring The BD WAY to life. You will help your
fellow associates be great, and you will build trust among them.
By creating a real opportunity to be heard and a sense of safety and
belonging, you will also foster our company’s culture of inclusion.

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Zero tolerance for retaliation

BD does not tolerate any form of retaliation. This applies to anyone who reports an actual or Advancing your
suspected violation of BD policy or cooperates in BD investigations. BD wants all associates to feel knowledge
comfortable asking questions, raising concerns, or seeking guidance without fear of retaliation.
Any BD associate who engages in retaliation will be subject to disciplinary action, up to and
What does retaliation* look like?
including termination of employment. If you believe someone has retaliated against you,
• Terminating, demoting, or suspending an
contact Human Resources or Ethics & Compliance.
associate
• Denying benefits
• Threatening or belittling an associate
• Passing over an associate for a promotion,
raise, or bonus
• Requiring an associate to meet
burdensome and unrealistic expectations
• Providing negative performance reviews
• Removing an associate from accounts or
projects
• Reducing an associate’s hours
• Ignoring an associate or leaving them out
of team events and meetings

* Retaliation is when these actions are taken because an

associate reported an actual or suspected violation of
BD policy or cooperated in a BD investigation.

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Reporting concerns
BD takes all reports of violations of laws, BD policies, and our high ethical
standards seriously. We promptly, fairly, and thoroughly investigate all
reports. The Ethics Office assigns an independent investigator to review
the facts. The Ethics Office monitors the investigation to ensure it
follows BD standards.
Everyone at BD must cooperate fully with any BD investigation or
audit. This includes answering questions truthfully, sharing all relevant
information, and protecting potential evidence. Anyone accused of
wrongdoing will get fair and objective treatment.
Confidentiality is a top priority for BD. We take care to keep your identity
confidential. This may not always be possible though due to the nature
of the issue, the need to conduct a more thorough investigation, or legal
requirements.
BD will take appropriate corrective action for any misconduct. Violations
may result in disciplinary action, up to and including termination of
employment. Serious violations could also result in legal liabilities for the
company and/or the involved individuals. See Our expectations.

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Being an ethical leader

Each of us must be an ethical leader. This means we do the right thing, Authentic answers
every time—even when it is not easy and even when no one is looking.
It also means we don’t compromise our values or ask anyone else to do so. Q An associate who reports to me came to me very upset about a
If you are a BD leader or manage people, you have a special duty to problem she’s having with a colleague from another department. She
foster a culture of ethics and integrity by: says she’s being harassed, but I’m not sure. Maybe she’s just being
• Serving as a role model and leading by example in all you say and do sensitive and overreacting. What should I do?
• Encouraging your team to speak up when they have concerns, listening
to those concerns, and handling them appropriately A Listen. Listen. And listen some more. It’s very important for your
• Ensuring your team has the knowledge and resources to perform their associate to know that you take her concerns seriously. Let her know
jobs in an ethical manner you’ll bring this matter to the attention of the Ethics Office so it can
• Talking to your team regularly about the Code and what ethical and be investigated and dealt with discreetly and appropriately. Reassure
compliant behavior means for them
her that you won’t allow retaliation of any kind to be directed against
• Making it clear that we never compromise our ethics to achieve her. Avoid jumping to conclusions.
business results
• Never retaliating or allowing retaliation against any associate who
reports an issue or raises a concern
• Recognizing and rewarding ethical behavior, addressing and correcting
inappropriate behavior, and doing so consistently
• Considering ethical character and behavior when making decisions
about hiring, promoting, and evaluating associates
• Taking action to prevent or stop violations of the Code or the law, and
ensuring issues are properly reported and addressed

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Applying our Code

Our expectations
Everyone at BD, from directors to officers and associates, must follow our Code of Conduct.
It applies equally to everyone, no matter their position or level. This is a condition of
employment at BD.
Note: Nothing in this Code creates or implies a promise or contract of employment.

Our responsibilities
At work, we must always make choices in line with our values and the Code. Among other
things, this means:
• Meeting our standards, as our Code sets out
• Never compromising our values to achieve our objectives
• Learning and following our Code, policies, and procedures, and all laws and regulations that
apply to our job
• Speaking up when we see or suspect someone isn’t following the Code, and asking for help when
it’s not clear what we should do
In short, we must always: ask questions, raise concerns, and seek guidance.

Waivers
Waivers of any provision of the Code are rare and may be granted only by the Chief Ethics &
Compliance Officer, in consultation with the General Counsel. Waivers for executive officers or
directors may only be granted by the Board of Directors and must be promptly disclosed to
shareholders.

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Fostering a respectful workplace. . . . 17

Upholding labor and
employment laws . . . . . . . . . . . . . . . . . 20
Keeping workplaces safe
and healthy. . . . . . . . . . . . . . . . . . . . . . . 21

Advancing the world of healthTM and achieving our goals is

Our people
possible only thanks to the dedicated and talented people
who work at BD. The health and well-being of people is at
the core of everything we do. That’s why it’s so important for us to
treat each other fairly and maintain a safe and healthy workplace.

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Fostering a respectful workplace

What we believe
Everyone deserves to work in a supportive, inclusive, and safe environment.
We treat everyone with dignity and respect.

Why it matters
Respecting others is an important factor for our success. We do
our best work when we feel safe and secure, knowing that our ideas
and talents will be recognized and respected. That’s why we never
tolerate discrimination, harassment, retaliation, bullying, or violent
conduct at work.

How we do what is right

Do:
• Treat one another with dignity and respect
• Speak up if you see anyone being harassed or threatened
in any way
Don’t:
• Say or do anything that others may find offensive
or degrading

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Fostering a respectful workplace (continued)

Supporting inclusion and diversity Preventing discrimination
We serve our customers best when we seek out and listen to a broad We will not be successful if we limit others. Instead, we do what’s right by:
range of ideas and opinions by: • Treating others fairly and focusing on the skills and experience
• Recruiting, hiring, and retaining the best talent from a wide range they bring to BD
of backgrounds • Using only merit and performance for decisions about hiring, training,
• Actively searching for different points of view discipline, and promotion
• Listening to the points of view of others with courtesy and respect • Never discriminating against anyone on the basis of “protected
• Speaking out when we feel our views or those of others are being characteristics”
disrespected These include:
• Race • Sexual orientation
• Color • Genetic
• Gender (including pregnancy, information
• Gender identity
childbirth, lactation, and
related medical conditions) • Gender
• Age expression
• National origin • Marital status

• Ancestry • Citizenship

• Pregnancy • Military or veteran status

• Physical or mental disability • Social class

• Medical condition • Any other characteristic

• Religious beliefs protected under applicable law

• Accommodating individuals with legally recognized disabilities

and/or religious beliefs

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Fostering a respectful workplace (continued)

Preventing harassment
We don’t tolerate harassment. Harassment is any unwelcome verbal
or physical conduct based on a “protected characteristic.” It may
also include conduct of a sexual nature. Harassment may create an
intimidating, hostile, or offensive work environment.
See “Preventing discrimination.”

Here are some examples of

sexual harassment: Authentic answers
• Inappropriate physical contact
• Sexually suggestive comments Q Lately I’ve noticed in meetings that some associates’ ideas
• Offensive language or images passed along by any means, aren’t recognized or that some people are often interrupted when
including the internet, email, voicemail, text, or instant message
they’re talking. I’m worried this is because of their gender. I don’t feel
• Unwanted advances or offers
comfortable pointing it out during the meeting. What should I do?
• Asking for sexual favors or offering employment benefits in
exchange for them
A Part of our commitment to inclusion and diversity is seeking
• Making derogatory comments or sexually explicit jokes
multiple viewpoints, which means providing a space for associates to
• Making comments about someone’s body
speak up. You should speak with the meeting leader or your manager.
• Using degrading words to describe someone
If you don’t feel comfortable doing that, contact Human Resources.
• Suggestive or obscene letters, notes, or invitations
• Any sexually suggestive behavior, such as leering, making gestures,
or displaying sexually oriented objects or pictures Get more information:
Equal Employment Opportunity Statement

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Upholding labor and

employment laws Advancing your knowledge
What we believe How does BD comply with wage and hour laws?
We respect everyone, and that starts here in our business.
BD is committed to paying every associate properly according to
We think that following the laws when it comes to labor and
applicable laws. To do that, we keep records of the hours worked by all
employment issues is not only the right thing to do, but it will
non-exempt (overtime eligible) associates. In most cases, we use an
also help our business grow. So, we follow all labor and
electronic system, which lets associates accurately record the time
employment laws to protect our associates and our business.
they’ve worked.

Why it matters There are notices in all work sites about wages and hours, including
We show respect for our people by creating a safe and fair place to work. the right to be paid for all hours worked. In the United States,
When people get fair and respectful treatment, they will have more “off-the-clock” hours are not allowed for non-exempt associates.
motivation, do better work, and gain more satisfaction from their work. We also post notices about what work qualifies as overtime and how
we calculate what associates are compensated for that type of work.
How we do what is right If you have any questions or want to raise concerns about hours or
wages, contact Human Resources or the Ethics Office.
Do:
• Provide working conditions, hours, and compensation that are
safe and fair
• Report any concerns about hours and compensation to
Human Resources Get more information:
HROne
• Choose suppliers who are committed to fair labor and sustainable
Expectations for Suppliers
sourcing practices that protect the health and well-being of workers
Global Human Rights Policy
and communities
Don’t:
• Allow child labor or forced labor by BD or our suppliers

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Keeping workplaces safe • Report any threats of violence directed at you or anyone else. That
includes anything, even if it’s outside work or on social media.

and healthy Contact law enforcement in case of imminent danger.

• Travel with reputable airlines and use BD preferred hotels. Follow travel
guidance and alerts issued by Corporate Security.
What we believe
Don’t:
Everyone deserves to be safe and healthy in the workplace. It’s important
to make sure our operations meet or exceed applicable health and • Take unnecessary risks in the workplace or tell anyone else to do so
safety laws. • Take shortcuts or bypass health and safety policies and procedures—
if you are pressed to cut corners, report it
Why it matters • Bring alcohol, illegal drugs, or other controlled substances onto BD
Our number one priority is making sure that our associates and all those property or be under their influence while at work
who visit us are safe. We also know that a healthy work environment is a • Smoke or vape on BD property
positive, enriching, and productive one. We make sure our workspaces • Bring weapons or firearms to work. That includes job sites and other
are free from hazards and allow us to thrive. We use environmental, work-related locations.
health, and safety management systems to achieve this.

How we do what is right

Do:
• Follow our health and safety policies and procedures
• Report unhealthy or unsafe conditions or behaviors. This includes
things like workplace hazards, broken or missing equipment, or the
presence of weapons on BD property. Contact law enforcement in
case of immediate danger.
• Know what to do in case of injury or other workplace emergencies.
You can do that by cooperating during emergency drills.
• Try to talk through disagreements calmly before they escalate

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Keeping workplaces safe and healthy (continued)

Authentic answers
Q I saw a former co-worker on social media threaten to hurt BD
associates. I don’t want to overreact or make the situation worse.
What should I do?

A We all have to help keep people safe. If you see or hear

anyone threaten to hurt someone or damage something, tell
someone right away. You can report it to your manager, Human
Resources, the Ethics Office, or Corporate/Site Security. When
there is an immediate risk to life or property, contact local law
enforcement immediately. Also, tell someone on the Corporate
Communications team, so they can monitor the situation.

Get more information:

Corporate Security site
Workplace Violence Policy
Weapons in the Workplace Policy
Environment, Health and Safety policy

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marketplace

Playing fair. . . . . . . . . . . . . . . . . . . . . . . .24

Dealing ethically with HCPs,
HCOs, and government officials. . . . 26
Following product rules.. . . . . . . . . . . .31
Scientific exchange. . . . . . . . . . . . . . . . 33
Ensuring product safety
and quality . . . . . . . . . . . . . . . . . . . . . . . 35
Promoting products honestly. . . . . . 37
Dealing ethically with
third parties. . . . . . . . . . . . . . . . . . . . . . . 39
Following international
trade laws . . . . . . . . . . . . . . . . . . . . . . . . 40

Our customers and the patients who use our products count
on us to do what’s right. We follow through on our

Our customers commitment to our customers and their patients by always

behaving ethically in everything we do. We follow all laws and
regulations that apply to us when we do business, wherever in the

and marketplace world that may be. We consistently provide superior products and
services that are safe and effective for our customers and patients.
We are fair and honest in all our business dealings.
We don’t cut corners. We don’t choose the easy way over the right way.

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marketplace

Authentic
Playing fair
answers What we believe
We will succeed as a business because we have ideas and technology that meet the needs of
customers and patients. We are fair and honest when we do business. We follow all the laws that
Q I always want to win. I try to encourage
govern how companies compete and behave with each other.
my team by telling them that we need to
crush the competition and block them from Why it matters
the market. Am I doing the right thing?
Fair competition laws, such as antitrust laws, promote healthy competition and protect consumers
from unfair business practices. We will win in the marketplace based on the value of our products
A Saying things like “crush the competition” and services.
may seem like just an expression of enthu-
siasm. However, it could also be seen by How we do what is right
regulators as a sign of illegal business Do:
practices. It can also create a culture where • Avoid any false or dishonest practices
people think winning is the only goal, and • Seek help from the Law Group if we want to compare our situation with a competitor
as a result start using deceptive or unfair or are unsure about how to act with competitors
tactics. Instead, focus on the value and Don’t:
benefits of our products and services. • Discuss pricing, contract terms, or marketing/sales strategies with competitors
We succeed because we have new and
• Agree with competitors to divide markets, territories, or customers
useful ideas and technology. That’s what
• Use our category position in an illegal or unethical manner to reduce, prevent, or
separates us from the competition. eliminate competition
• Make agreements with customers or sales channels like distributors to restrict resale prices
• Make false claims or disparaging comments about our competitors’ products or intentionally
interfere with their business relationships

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marketplace

Playing fair (continued)

Authentic Competitive intelligence
answers To compete effectively, we must understand our evolving industry and our competitors.
However, we must gather and use information about our competitors responsibly and ethically.
Q A nurse working for one of our We should treat other companies and their information as we would want them to treat us.
customers sent me pricing information
and contract terms from one of our How we do what is right
competitors. The nurse didn’t think it was Do:
confidential. Can I use this information to • Use publicly available sources whenever possible
prepare a bid to win business currently • Follow any confidentiality or nondisclosure agreements when we can see another
held by the competitor? company’s information
• Respect our competitors’ rights regarding their intellectual property and
A No. The information could be confidential information
confidential, even though the nurse didn’t Don’t:
think so. Using that information may not • Ask for sensitive or confidential business information from competitors or their customers
be ethical and could conflict with our • Use illegal methods such as trespassing or theft to get information about other companies
Code. In this situation, it’s best to contact • Hire or talk to former employees of competitors to get confidential information
the Law Group for guidance.
Get more information:
Global Antitrust and Competition Law Policy

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Dealing ethically with HCPs,

HCOs, and government
officials
What we believe
Strong, long-term relationships with healthcare professionals (HCPs),
healthcare organizations (HCOs), and government officials (GOs)
help us better understand our customers and their patients’ needs.
Through collaboration, we continue to develop high-quality products
and teach people about their safe and effective use. These relationships
must be based on the highest ethical standards.

Why it matters
Law and industry codes around the globe set high standards that govern
our interactions with HCPs, HCOs, and GOs. These relationships must
always be grounded in a legitimate business need and never be used to
secure an improper business advantage. If we can’t develop these types
of relationships, build trust, and sustain them over time, our reputation
will be damaged and our business will suffer. If we make mistakes, the
consequences are severe.

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Dealing ethically with HCPs, HCOs, and government officials (continued)

Fighting bribery and corruption
We don’t accept, offer, or approve bribes of any kind. A bribe or Advancing your knowledge
“kickback” is anything of value meant to gain an improper business
advantage. It also applies if we attempt to get favorable treatment from We never offer, give, or accept anything of value* to improperly
a government official. It’s critical that we avoid even influence decisions or to get an unfair advantage. These might include:
the appearance of trying to bribe someone.
• Cash or cash equivalents
We follow anticorruption laws in many countries, including: • Gifts
• U.S. Foreign Corrupt • China Anti-Unfair • Entertainment, hospitality, or meals
Practices Act (FCPA) Competition Law • Travel expenses
• U.S. Anti-Kickback Statute • Brazil Clean Companies Act • Services
• U.K. Bribery Act • Offers of a job or educational opportunities
• Loans or cash advances
How we do what is right
• Grants, donations, or contributions
Do: • Free of charge products
• Know how to recognize and avoid a bribe • Any other transfer of value, including favors for family
• Follow our Global Antibribery & Anticorruption Policy, Global members, even when it’s a small amount
Third-Party Intermediary Life Cycle Management Policy, and
Free of charge products
our Global Standards for Interactions with HCPs, HCOs, and
We can give products to customers in certain situations. This applies, for
Government Officials
example, when we want to demonstrate the product or let a potential
• Be aware of how our actions might appear to others
customer evaluate if a product fits their needs. Provide only the
• Record all payments and expenses accurately
minimum amount of product needed for the minimum amount of time
• Speak up if you see or suspect bribery
required. Make sure documentation accompanies any free of charge
• Seek advice from your local Ethics & Compliance representative product/trial use product. Keep track of any free of charge product, and
Don’t: act quickly to get products returned once customers have reached the
• Use a third party or someone else to make illegal payments or end of the agreed trial use period.
sidestep BD policies *Some items of value may be provided in limited situations for legitimate reasons. For example,
we can pay for travel expenses and provide free of charge equipment in some cases. Consult
• Make any payment meant to “facilitate” routine services from a your Ethics & Compliance representative for guidance.
government official, unless it’s to protect your personal safety
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Dealing ethically with HCPs, HCOs, Don’t:

• Work with an HCP without a proper written agreement
and government officials (continued)
• Attempt to interfere with an HCP’s independent medical judgment
Collaborating ethically with healthcare professionals • Make arrangements (including grants, donations, or contributions)
We can and should collaborate with HCPs for many reasons. intended to reward or encourage an HCP to purchase, lease, or
These include: recommend our products
• Product development • Advisory panel meetings
and improvement • Scientific meetings
• Clinical studies or research • Consulting arrangements
• Speaking engagements • Other legitimate services
• Training and education on the
safe and effective use
of BD products

How we do what is right

Do:
• Engage with HCPs only if we have a legitimate need
• Choose only qualified HCPs to meet our legitimate needs
• Select locations and venues to interact that are modest
and appropriate
• Always follow our HCP Meal Limits Guidelines and only pay for modest
travel expenses
• Pay HCPs fair market value for their services as described in our
HCP Fair Market Value Compensation Guide
• Make sure clinical studies and research meet the highest ethical,
medical, and scientific standards. Medical Affairs must always be
involved in clinical study and research initiatives.

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Dealing ethically with HCPs, HCOs,

and government officials (continued) Authentic answers
Items provided to HCPs, HCOs, and GOs
Q During a sales negotiation, a large HCO requested funding for
Giving or accepting gifts or other items can create the perception of a
an investigator-sponsored study. Is it appropriate to provide a
conflict of interest or exposure under antibribery and corruption laws.
That’s because it could seem as though we’re giving the item to get research grant to help secure the sale?
favorable treatment. Important and specific rules apply to gifts, A No. Sales and research activities need to be kept separate. We can
entertainment, educational items, and other business courtesies to
never use a grant to encourage an HCP to purchase, lease, or recommend
HCPs, HCOs, and GOs.
our products. All requests for investigator-sponsored studies must be
How we do what is right submitted via CyberGrants so the right committee can review it.

Do:
• Provide items to HCPs that benefit patients or serve a genuine
educational function. Before offering any item to HCPs, HCOs, Innovation through integrity
or GOs, make sure that the item is allowed under BD policies,
applicable laws, and industry codes. Many countries have specific
Throughout our history, we’ve worked on R&D programs with
requirements restricting items that may be given to HCPs.
universities, medical centers, and other organizations. There are many
Don’t:
examples of how these relationships have resulted in some of our
• Give gifts of any kind, such as cookies, wine, flowers, chocolates,
greatest innovations. For example, our unique collaboration with
holiday gifts, gift baskets or gift certificates, and cash or cash
equivalents, even for significant life events, like weddings, births, Singularity University, a California corporation that applies technology
anniversaries, or funerals. However, outside the United States, you to some of the world’s greatest challenges, resulted in three important
may provide a modest gift for the death of an HCP or their projects. These projects:
family member. • Explored the use of real-time data gathering for home-based
• Pay for or facilitate entertainment, personal travel, or recreation of disease management
any kind for HCPs or GOs • Created predictive analysis on patient behavior
• Built new visualization tools for high-parameter cell analysis

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Dealing ethically with HCPs, HCOs,

and government officials (continued)
Transparency laws
Laws and industry codes in many countries require that we report HCP
and HCO payments (or certain other transfers of value) to government
organizations and/or the public (for example, the U.S. “Sunshine Act”).
To do this, we must keep accurate records of all payments. That means
following our Transparency policies and processes.

Get more information:

Global Transparency site
Global Investigator Sponsored Studies Policy
Global Standards for Interactions with HCPs, HCOs, and Government Officials
Global Antibribery & Anticorruption Policy
Global Free of Charge Products Policy
Global Third-Party Intermediary Life Cycle Management Policy

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Following product rules • Make sure all information we keep or send to government agencies
is truthful, accurate, and complete
• Only sell products that are authorized and meet all applicable regulatory
What we believe requirements
When we follow the rules for our products, we help ensure they are safe
• Properly label, advertise, and promote our products
and effective. This will build and maintain trust with our customers,
• Promptly report complaints, adverse events, and other signs of potential
their patients, and government agencies.
product problems
Why it matters Don’t:
Our reputation and ability to sell our products depends on following the • Assume the rules in your home country are the same in other countries
rules and regulations in each country where we operate. Our Regulatory • Assume someone else will speak up; if you learn of a problem or have
Affairs, Quality Management, and Medical Affairs functions all play concerns, speak up so it can be addressed
critical roles in helping us do that. • Suppress information that could impact compliance with safety and
We follow the rules of government agencies, health ministries, and quality standards
regulatory authorities around the world. A few examples of these
organizations are listed below:
• FDA (U.S.)
• Therapeutic Goods Administration (Australia)
• Health Canada (Canada)
• Ministry of Food and Drug Safety (South Korea)
• National Medical Products Administration (China)
• National Health Surveillance Agency (Brazil)
• Medicines & Healthcare Products Regulatory Agency (U.K.)

How we do what is right

Do:
• Make sure all products are developed using the appropriate controls and
that they pass all appropriate testing before we market and sell them

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Following product rules (continued)

Authentic answers Innovation through integrity

Q I was at a party, and I overheard some guests talking about a More than 20 bloodborne diseases can be spread by accidental
BD product. They were complaining about some side effects. Should needlestick injuries (NSIs). BD pioneered the development of safety-
I report this? engineered products to address this issue and continues to be a
leading supplier of these technologies.
A Yes. We take product complaints very seriously, not only because
we always want to be improving our products, but also because of the Our proactive commitment to healthcare worker safety doesn’t end
rules and regulations that apply. You should report product complaints to with our extensive, innovative product portfolio. BD led the charge for
the right people, even if you hear them outside of work. The Product healthcare worker safety legislation and continues to advocate on
Complaint Form on the Maxwell homepage is the best place to do that. behalf of nurses and organizations. BD helps to develop and share
best-in-class practices and provides open access to training and
education to keep healthcare workers safe.

Get more information:

Product Complaint Form

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Scientific exchange
What we believe
Making sure our products are safe and effective is a top priority. We
can’t promote or advertise any off-label use of our products. But there
are important public policy reasons for our Medical Affairs associates
to engage in scientific discussions with the external healthcare community
related to both on- and off-label uses of our products.

Why it matters
We want to be a trusted and valued scientific partner in developing
products that help improve patient care. We also want to help healthcare
providers do their jobs more efficiently. Scientific exchange helps us do
that, but there are strict requirements. Our scientific exchange principles
also make sure we follow applicable legal requirements and that we
protect our credibility and our stakeholders’ trust.

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Scientific exchange (continued)

How we do what is right
Do:
• Separate all scientific exchange activities from commercial and
sales activities
• Make sure all scientific exchange communications are non-promotional,
balanced, objective, scientifically rigorous, and conducted by appropriately
trained Medical Affairs associates
• Support independent continuing medical education programs in
accordance with our Global External Funding Policy
• Make sure clinical trials are conducted ethically and follow BD policies,
all applicable laws, and regulatory requirements
• Respond to unsolicited requests for information about off-label use by
first stating that the topic is off-label, and BD recommends use of its
products in accordance with the approved labeling. Then refer the
person making the request to your local Medical Affairs contact.
Don’t:
• Take part in any scientific exchange activity if you work in sales,
marketing, or any other commercial function
• Share scientific information that is not balanced with accurate risks Get more information:
and benefits (such as focusing on positive data only) Global External Funding Policy
• Engage in proactive conversations about off-label use or solicit Global Human Subject Research Policy
requests for off-label information Global Data Disclosure and Publication Policy

• Suggest an investigational product or use is safe or effective

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Ensuring product safety

and quality
What we believe
The safety of patients and users of our products are a top priority. We
think about the patient and healthcare professional during every step of
development and production. We all need to make sure that BD products
and technologies meet appropriate safety and quality standards.

Why it matters
To help in successful diagnosis and treatment, BD products must be safe
and effective for their intended use. Our customers and patients are at
the heart of everything we do, and they depend on the quality and
safety of our products. We never cut corners.

BD Quality Policy
“ We will consistently provide superior products and services in
pursuit of our Purpose of advancing the world of healthTM. This will
be achieved through customer-focused continuous improvement
and by maintaining an effective quality system which complies
with regulatory requirements.”
—Tom Polen, Chairman, CEO, and President

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Ensuring product safety and quality (continued)

How we do what is right Advancing your knowledge
Do:
• Follow quality system regulations, standards, policies and procedures,
Report any product complaint using the Product Complaint Form on
and good manufacturing practices
the Maxwell homepage within 48 hours of learning about it. Every BD
• Make sure our products are produced in an environment that
associate is responsible for reporting any product quality or safety
promotes quality and consumer safety
issues as quickly as possible so we can address them.
• Take personal responsibility for the success of our business by
immediately reporting any quality or safety concern
What is a product complaint?
Don’t:
A product complaint alleges quality or safety issues. Complaints can
• Bypass quality controls or take shortcuts that compromise the quality
or safety of our products come in many forms, such as an email, a text, a letter, a phone call,
or even a comment over coffee. The important thing is that someone
is saying that the product doesn’t work as it should after we’ve started
to sell it.

Get more information:

BD Quality Policy

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Promoting products honestly How we do what is right

Do:
What we believe • Promote only products authorized for sale in your country
We’re honest, open, and proud when we share the benefits of BD products, • Make sure our labeling, advertising, and promotional materials meet
solutions, and services with customers and patients. We build trust and all applicable requirements as set forth in BD policies
confidence in our products and technologies by promoting products • Use only advertising and promotional material that has been properly
honestly and supporting our claims with evidence. approved in accordance with BD policies
• Make accurate, truthful, and balanced claims about our products
Why it matters backed up by appropriate product testing or clinical data
Long-lasting customer relationships and our good reputation depend • Share information about reimbursement and health economics for our
on trust supported by integrity. So we’re honest and open about our products that is honest and does not interfere with independent
products and technologies, and we never mislead our customers. Product medical decisions
advertising and promotion are also subject to strict legal requirements, Don’t:
including that all advertising and promotional claims must be on-label,
• Promote products before getting approval to market them
truthful, not misleading, and not unfair or deceptive.
• Suggest or encourage any unapproved or off-label uses of products
• Exaggerate the benefits of our products and technologies or hide the
potential risks of using them
• Make claims that are not supported by appropriate product testing or
clinical data
• Make false or disparaging claims about competitors
• Make any changes to approved advertising or promotional material or
create your own

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Promoting products honestly (continued)

How we market our products Authentic answers
For BD to achieve its Purpose of advancing the world of healthTM,
we must do what is right. The Global Policy on Advertising and
Q I found a news article online that discusses an amazing patient
Promotion sets out the principles and rules about how to create, review,
success story from using a BD product. Can I share this
and approve advertising and promotional materials for BD products to
ensure compliance with all applicable laws and regulations, as well as to with customers?
maintain our reputation for honesty with our customers.
A Although BD did not write the news article, if we use materials
BD provides guidance and more detail on the requirements for these areas like this that are created by third parties, our regulators can hold us
related to advertising and promotion: responsible for their content. This news story should not be shared
• Claim substantiation with customers unless it is first reviewed and approved through
• Disease awareness communications the Global Advertising and Promotion Review, Approval and
• Internet-based platforms Escalation Process.
• Presenting balanced product information in ad prom materials
• Promotion of Research Use Only (RUO) and Investigational Use
Get more information:
Only (IUO) products
Global Advertising and Promotion Review, Approval and Escalation Process
• Promotional distribution of publications Global Policy on Advertising and Promotion
• Speaker programs and events Product Complaint Form
Claim substantiation
• Trade shows
Disease awareness communications
• Use of case studies and testimonials in ad prom materials Internet-based platforms
Before we use any advertising and promotional materials, we must Presenting balanced product information in ad prom materials
Promotion of RUO and IUO products
review and approve them according to the Global Advertising and
Promotional distribution of publications
Promotion Review, Approval and Escalation Process. BD associates
Speaker programs and events
may not change approved materials or create their own promotional Trade shows
materials. Use of case studies and testimonials in ad prom materials
Global Health Care Economic Information (HCEI) Policy

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Dealing ethically with • Protect any confidential information we get from third parties and use
it only for proper purposes

third parties • Speak up if you suspect a third party is violating our Code or any of
our policies
What we believe • Monitor third parties for as long as we work with them
Our third-party partners are vital for our success, so we choose them Don’t:
carefully. At BD, a third party might include our distributors, service providers, • Ask or let a third party do anything that violates our Code, policies,
or consultants, to name a few. We treat them with respect and expect or the law
them to meet our ethical standards. They must share our commitment to • Accept or offer bribes or kickbacks
ethics and quality. They must also provide the best value for BD.
• Work with a third party unless we’ve vetted them using our
internal processes
Why it matters
• Make any side agreements like keeping business away from
We work hard to build our reputation and earn the trust of our customers. another supplier
It’s important that partners working on our behalf help us protect that
reputation and trust. That’s because under the many laws that apply
to us, we can be held responsible for anyone acting on our behalf.

How we do what is right

Do:
• Deal fairly and honestly with all third parties
• Choose third parties based on a legitimate business need and their
qualifications to meet that need, not for improper purposes. Use an
open and fair selection process.
• Let business partners know that we expect them to follow our
values and applicable policies. Share our Global Antibribery &
Anticorruption Policy and our Expectations for Suppliers. Get more information: Global Third-Party Intermediary Life
Global Antibribery & Cycle Management Policy
• Avoid any possible conflicts of interest when choosing or dealing with Anticorruption Policy Expectations for Suppliers
third parties and disclose any personal relationships with third-party BD Procurement Purchasing Policy
representatives
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Following international
trade laws
What we believe
We believe in thinking globally. As a global citizen, we follow all
applicable international trade laws worldwide.

Why it matters
We operate all over the world. Our global business is subject to laws
and trade restrictions for the import, export, and reexport of products,
including software, technology, components, and raw materials.
Following these laws helps maintain our reputation for fairness,
honesty, and integrity. If we don’t follow these laws, we can be subject
to civil and criminal penalties that may include suspension or denial of
international trade privileges.

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Following international trade laws (continued)

How we do what is right Don’t:
Do: • Do business with sanctioned countries/regions including Cuba, Iran,
North Korea, Syria, or the Crimea region without Law Group approval
• Know the import regulations related to marking and labeling of goods,
valuation of goods, payment of duties, and record keeping for our • Do business without proper approval with entities or individuals that
products, services, and technology are on restricted parties lists*
• Know the requirements for export and reexport. An export can include • Allow products to be sent to a different destination than originally
physically or electronically sending a product or technology across an planned unless such an arrangement is permitted under our policies
international border. An export can also be providing a service to *The U.S. and other governments maintain lists that contain information
someone in another country. Or it can even be just sharing information about persons, foreign government agencies, companies, organizations,
with a foreign national. Reexport generally involves the shipment or and other entities with which companies are restricted, in varying degrees,
transmission of U.S. origin product or technology from one non-U.S. from engaging in trade transactions.
country to another.
• Know your customer and their use of our products and services
• Conduct risk assessments and due diligence checks on third parties
with whom you intend to do business
• Accurately classify and report the value, quantity, and country of origin
for all imports to customs officials, and use reasonable care with
respect to import activities
• Alert the Law Group if a customer, supplier, or anyone else asks us to
participate in a prohibited boycott
• Talk to Global Trade if you have any concerns or questions about
international trade

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Following international trade laws (continued)

Advancing your knowledge Authentic answers

Anti-boycott laws Q One of our distributors told me they can get our products into
We must follow laws in the United States that prohibit participation in Syria by first shipping them to a country that does not have trade
international boycotts that the U.S. government hasn’t approved, such restrictions with Syria. He said it’s above board. Can I do it?
as the Arab League boycott of Israel. The law’s scope is broad and
complex, and may not allow us to: A No. This is an example of product diversion and is an attempt to
• Do business with certain parties or countries break contractual agreements, trade restrictions, or other regulations.
• Provide information about business relations with certain parties Unless required by law, we also don’t allow product diversion because it
• Pay, honor, or confirm letters of credit containing boycott makes it harder for us to:
provisions • Track our products
Because anti-boycott laws are complex, talk to the Law Group right • Make sure there are adequate supplies in each region
away about any requests that may deal with these issues. • Follow international trade laws and other legal requirements

Get more information:

Global Trade site
BD Trade Compliance Procedure

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and shareholders

Avoiding conflicts of interest. . . . . . . 44

Preventing insider trading. . . . . . . . . 47
Protecting personal data. . . . . . . . . 49
Protecting our assets. . . . . . . . . . . . . . 52
Safeguarding confidential information
and intellectual property . . . . . . . . . . 54
Maintaining accurate records
and accounts. . . . . . . . . . . . . . . . . . . . . 56
Safeguarding our reputation. . . . . . . 58

When advancing the world of healthTM, we must protect the

Our company
company and its value for shareholders. Each of us creates
value for our company and its shareholders by acting in the
company’s best interests, protecting personal data and our assets,

and shareholders
using assets properly, making sure our business records are accurate,
and protecting our public image. Doing what is right in these ways will
help create long-term success for our company and everyone with a
stake in its future.

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and shareholders

Avoiding conflicts of interest Advancing your knowledge

What we believe
As associates, we are loyal and place the company’s interests Some examples of potential conflicts of interest are:
over our personal interests. We avoid conflicts, or the appearance of • Personal relationships: You supervise or conduct business with a
conflicts, between our personal interests and the company’s family member or with someone with whom you have a personal
interests. relationship
• Outside activities: You let a second job or activities with another
Why it matters organization hurt your performance, or get in the way of your role at BD
How we act when we do business affects our reputation and the trust • Use of BD assets: You use BD property, information, or resources for
we have earned with stakeholders. Conflicts of interest can affect the personal benefit or to benefit others
decisions we make for BD or create the appearance of unfairness or • Financial interests: You or a family member invests in or has other
bias in our jobs, which could hurt the trust we’ve built. financial interests in a company that does business or competes with
BD (or wants to)
How we do what is right • Business opportunities: You take an opportunity that came to you
Do: as a result of your work with BD without first offering it to BD
• Family members: You let a family member get benefits they
• Learn to recognize a potential conflict of interest
shouldn’t, based on your position with BD
• Tell a manager or the Ethics Office right away about any situation
• Accepting gifts: You accept an improper gift from a supplier or
that might be a conflict of interest. Most conflicts can be avoided or
vendor. See Accepting Gifts and Entertainment from Suppliers
sorted out if managed properly and quickly.
for more information.
• Ask for advice if you aren’t sure whether something is a conflict of interest
• Check the Global Conflicts of Interest Policy for the most up to
date information
Don’t:
• Use information obtained at work regarding a potential business
opportunity to invest in or develop opportunity for personal gain

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Avoiding conflicts of interest (continued)

Advancing your knowledge

Is it a conflict of interest? Ask yourself:
• Will it get in the way of your job with BD?
• Will it impact your ability to make good and unbiased business
decisions for BD?
• Will you use BD assets?
• Could you or a family member get something of value based on your
position at BD?
• Could someone else reasonably worry there was a conflict of interest?
• Would the company’s reputation be hurt if it became public?
• Would it pose an unfair advantage for BD?

Authentic answers
Q A vendor has asked me to join their advisory board, but I’m
not sure if this represents a conflict of interest. What should I do?

A Outside work can create a potential conflict of interest. Serving on

a vendor’s advisory board may appear to give that company an unfair
advantage. It may be okay, though, depending on the circumstances.
You should tell your manager and talk with the Ethics Office about
your situation to get guidance on whether or not you can participate.

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Avoiding conflicts of interest (continued)

Accepting gifts and entertainment from suppliers
Advancing your knowledge
Strong relationships are important to our success at BD, and sometimes Acceptable gifts may include:
it may be polite and appropriate to accept modest gifts and hospitality,
• Corporate logo items such as mugs, pens, T-shirts, etc.
such as lunches or dinners.
• Regional or cultural gifts such as local souvenirs
The BD Travel & Expense Policy includes guidance on what we
• Holiday ornaments of nominal value
consider to be a modest meal and what is acceptable. Although
• Food gifts of nominal value such as fruit baskets
associates can accept a meal while engaged in a business purpose, they
should not accept meals that exceed the values listed in the BD Travel
& Expense Policy, even if someone else is paying for the meal.

How we do what is right

Do:
• Accept gifts or hospitality if they are nominal in value and infrequent
• Share gifts like promotional items or gift baskets with team members
when possible
• Know that the rules for giving gifts to healthcare professionals,
customers, or government officials are much stricter. See Items
provided to HCPs, HCOs, and Government Officials for more
information.
Don’t:
• Accept cash or cash equivalents, like gift cards Get more information:
Global Conflicts of Interest Policy
• Accept gifts or hospitality if they break any laws
Items provided to HCPs, HCOs, and Government Officials
• Accept gifts or hospitality if they affect or appear to affect your BD Travel & Expense Policy
ability to make good, unbiased business decisions for BD
• Ask for gifts or hospitality

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and shareholders

Preventing insider trading Authentic

What we believe answers
We do not engage in insider trading. We do not share information about
BD or another company that isn’t already public, and we never use that
Q While I was having dinner with my extended family, my uncle
type of information for personal gain or to benefit anyone else.
asked, “Anything new at work?” I said, “Some big changes are coming.

Why it matters The FDA is going to approve a new device. Business is going to be
booming!” Was it okay to share this information?
Using material, nonpublic information to get financial benefit, often by
buying or selling shares, is unfair, distorts markets, and erodes the trust
of our customers and their patients. It’s a serious violation that can carry A No. It may have seemed like you were just making conversation,
significant penalties, including termination of employment, fines, and but this is an example of “tipping.” You shared material, nonpublic
even imprisonment. information. If your uncle used that knowledge to buy BD stock, that
would be insider trading.
How we do what is right
Do:
• Learn what insider trading is—see “What is insider trading?”
for more information
• Protect inside information from being released or distributed
• Share inside information with BD associates only if they need to know
Don’t:
• Buy or sell BD or other companies’ shares or securities based on inside
information or during a blackout period
• Engage in “tipping” or share inside information with others so they
can profit from it

© 2018 NYSE Group

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Preventing insider trading (continued)

Advancing your knowledge

What is insider trading?
Insider trading is when you buy or sell stocks or other securities based on
inside information—what is called “material, nonpublic information”—or
when you share that information with someone who then trades (also
known as “tipping”).

Material information is knowledge that may affect the price of a

stock or security or that an investor would likely consider important
when deciding whether to buy, sell, or hold stocks or securities.

Nonpublic information (or “inside information”) is knowledge that only

people within the company or associated with the company are aware
of. Information is considered public 24 hours after it has been released
to the market.

Examples of inside information for BD:

• Changes in senior management
• Approvals, launches, recalls, or other significant events regarding our
products
• Government investigations
• Market and customer strategies
• Financial results, projections, and forecasts
• Plans for joint ventures, mergers, acquisitions, or divestitures Get more information:
• Unannounced stock splits or stock repurchases Insider Trading and Securities Transactions Policy
Corporate Secretary site
• Increases or decreases in dividends paid by BD

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and shareholders

Protecting personal data

What we believe
We believe in making sure that personal data entrusted to us stays that
way. It doesn’t matter whether that personal data belongs to associates
or third parties, or is protected health information (PHI) of patients. We
collect, use, keep, and share personal data in compliance with privacy
laws.

Why it matters
Our success in advancing the world of healthTM means that sometimes
we need to access, use, and share some types of personal data. Our
customers, their patients, and our associates trust us with their personal
data. We will only be able to keep that trust if we protect their privacy,
honor the promises we make to use their personal data in appropriate
ways, and keep that personal data safe.
Privacy laws such as the Health Insurance Portability and Accountability Act
of 1996 (HIPAA) in the U.S., the European Union’s General Data Protection
Regulation (GDPR), and other global or regional privacy laws set conditions
on how we can use and share personal data and how to protect it. As new
privacy laws evolve rapidly, we are working to make GDPR privacy practices
a model for our global privacy program.

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and shareholders

Protecting personal data (continued)

How we do what is right • Know that personal data is anything that can be used alone
or combined with other available knowledge, to identify a person.
Do:
This includes, but is not limited to, things like:
• Understand whether your job responsibilities require you to handle
personal data especially in the case of protected health information
• Name

• Understand and follow all privacy and data protection laws, such
• Date of birth
as HIPAA and GDPR • Place of birth
• Use, access, or share personal data only for legitimate business • Employee or government ID number
purposes and in compliance with the law and BD policies • Patient ID number
• Ensure that privacy considerations are addressed throughout each • Physical or email address
step of the information life cycle: collection, use, disclosure, retention,
and destruction of personal data • Photographs or videos
• Tell your manager or the Privacy Office right away about any • Physical characteristics such as height or weight
potential loss or exposure of personal data • Medical conditions and treatment
• Protect personal data contained in our products and software technolo- • Race and ethnicity
gies, following a privacy-by-design approach during the entire process
from the design and concept phase to post-sales support Don’t:

• Maintain reasonable and appropriate administrative, technical, and • Share personal data with any person who doesn’t have a business
physical safeguards needed to protect protected health information need to know, even if they’re authorized to get it
(PHI) stored electronically (e-PHI) or in other forms • Share personal data with any other company or individual unless
we have a written agreement and they have appropriate
controls in place to protect it

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and shareholders

Protecting personal data (continued)

Innovation through integrity Advancing your knowledge

BD includes product security in our development process. For example, What is a personal data breach?
in networked products, we test security by attempting to hack the A personal data breach is when personal data is exposed to people
product, along with probing product security management plans, not allowed to see or use it and it leads to the unauthorized
sending out patches to improve security, and thinking about how to destruction, loss, change, disclosure, or access of the personal data.
manage any weak spots. Our Product Security team uses a three-
Examples include:
pronged strategy to make sure our products are:
• Access by someone who is not allowed to see it
• Secure by design
• When personal data is sent to the wrong person
• Secure in use
• Loss or theft of a laptop or phone containing personal data
• Secure through partnership, by working with customers
• Changes to personal data without permission
• When access to personal data is lost

If you suspect a personal data breach, contact your manager, the

Privacy Office, the Ethics Office, or the Ethics Helpline right away.

Get more information:

Global Privacy Policy
GDPR Data Protection Policy
HIPAA Privacy, Security, and Breach Notification Rules – Policies and Procedures
Product Security policy

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and shareholders

Protecting our assets

What we believe
We take care of the things we own so that we can make sure product innovations and
improvements can continue. This is one way we can help our customers and meet the
needs of patients around the world.

Why it matters
Our company’s assets, simply put, are what we own. They’re the result of the investment,
innovation, and hard work of our associates, past and present. They’re a vital part of
efforts to make sure patient health advances and BD continues to profit and maintain a
competitive advantage.

How we do what is right

Do:
• Treat BD assets as you would your own
• Take reasonable steps to make sure BD assets aren’t damaged, abused, wasted, lost, stolen,
or improperly transferred outside BD
• Use information and communications systems, and the electronic data they contain,
in a responsible manner
• Always handle our funds honestly and responsibly, and follow our policies
• Tell your manager or the Law Group about any abuse or misuse of our assets
Don’t:
• Take any of our assets away from our facilities for personal use
• Allow unauthorized people—including friends and family—to use our assets

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and shareholders

Protecting our assets (continued)

Advancing your Authentic answers

knowledge
Q In my spare time, I have an online business selling collectibles. When I have downtime
Assets come in many forms. Some at work, I sometimes check the status of orders and respond to customer questions. Since it
examples include: doesn’t interfere with my work, is this okay?
• Physical assets such as land, buildings,
office supplies, furnishings, machinery,
A While associates can use our computer network for modest nonbusiness purposes, you can’t

chemicals, warehouse equipment, use our assets, including computers, for your own business. You’re also not allowed to use our
documents, vehicles, computer computers to visit websites with content that’s not suitable for the workplace (for example, sexual
equipment, and phones content) or to stream nonbusiness videos.
• Electronic assets such as data and files
contained in our systems and servers
• Financial assets such as money
and anything that can be converted
to money, like stocks, bonds, loans,
and deposits
• Information assets such as any
information or data related to BD
business, including personal data
• Intangible and other assets such as
ideas, inventions, copyrights, trademarks,
patents, trade secrets, our brand, and
our reputation

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and shareholders

Safeguarding confidential How we do what is right

We must all protect our confidential business information and
information and intellectual intellectual property.

property Do:
• Make sure documents, data, and devices are safe. Use physical
measures like locked doors or drawers, as well as passwords and
What we believe encryption for electronic data.
Part of what gives us an advantage over our competitors is our confidential • Know what information is confidential, what restrictions apply, how
business information and our ideas and knowledge—what’s often called long to keep it, and how to get rid of it properly
intellectual property or IP. We must protect our intellectual property from
• Make sure that only people with permission visit our buildings
being shared without permission or from being misused.
and factories, and that they have escorts and do not enter
areas that are off limits
Why it matters
• Tell a manager or the Law Group if any information is released or
Our confidential information and intellectual property are among our
exposed when it shouldn’t have been, so we can address the problem
most valuable assets. Advancement in healthcare as well as our success promptly and properly
depend on improving and developing new products and technology. We
Don’t:
maintain our competitive advantage and enhance our impact on society
by protecting the confidential information and knowledge we own. • Share confidential or proprietary information with others—even inside
our company—unless they are allowed to and have a legitimate
business need to see the information
• Discuss confidential matters in public places, like elevators, trains,
or restaurants
• Make it easy for people to view confidential information (for example,
by working on a laptop on an airplane or using an unsecured
Wi-Fi network)
• Share passwords for our network, phones, or laptops
• Download files without proper permission to an external
device (such as a USB)

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Safeguarding confidential information and intellectual property (continued)

Advancing your knowledge Authentic

answers
Confidential information includes: • Research and development ideas and
• Proprietary information, such as industrial information Q I sometimes work remotely, so I email
designs and chemical formulas • Manufacturing processes the documents I need to my personal email
• Trade secrets and other intellectual property • Procurement information account for easy access. I particularly like to
• Financial information that isn’t public, • Associate information, such as work at my neighborhood coffee shop.
including pricing and projections compensation data Is this okay?
• Sales and marketing plans • Information concerning potential
• Customer and supplier lists acquisitions, investments, and divestitures
A No. We are all responsible for protecting

• Legal opinions and attorney work product our confidential information and intellectual
property. You should never email confidential
or proprietary documents to your personal
email for many reasons, but most importantly
because it is not secure. Also, you should
never use a public Wi-Fi network to download
confidential documents. You should even
make sure your home network meets the
requirements needed to keep our infor-
mation secure.

Get more information:

Trade Secret Policy
BD Information Security Policy
BD Information Security Standards

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and shareholders

Maintaining
accurate records
and accounts
What we believe
We believe in keeping good records. We keep
honest, complete, and accurate records so we
can make responsible business decisions and
be honest with investors and government
agencies.

Why it matters
Keeping reliable records helps us make good
business decisions and improves our efficiency.
Also, as a public company, BD is required by
securities laws to maintain accurate records
and to disclose information about our business
and financial performance in a timely manner.
Doing that well helps fulfill our obligations and
keeps the confidence of shareholders, customers,
business partners, and other stakeholders.

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and shareholders

Maintaining accurate records and accounts (continued)

How we do what is right
Do:
Authentic answers
• Comply with generally accepted accounting principles, internal
controls, policies, and all relevant laws and regulations
Q I recently had a business dinner with work colleagues and my
• Maintain documents that honestly reflect financial transactions,
spouse attended. I paid for the entire meal on my company card. I
without material misstatement, exaggeration, or unsubstantiated
estimates did not list my spouse as an attendee on my expense report and did

• Record all accounting entries and business transactions completely, not reimburse the company because I didn’t seek reimbursement for
accurately, in a timely manner, and in the proper period other business expenses that exceeded the cost of my spouse’s
• Submit accurate records to internal and external auditors on time dinner. Is this okay?

• Tell your manager about anything that may be inaccurate, false, A No. Your expense report did not accurately reflect the expense. In
or misleading
addition, using your company credit card for any personal use is against
Don’t:
our BD Travel & Expense Policy.
• Use any cash funds or other assets or liabilities that are secret
or unrecorded
Get more information:
• Mislead or misinform anyone about our business operations or finances
BD Travel & Expense Policy
• Create false documents or violate our Code because of any actual or
perceived pressure to achieve a financial goal
• Agree to any contracts with terms and conditions that don’t properly
reflect the actual relationship
• Destroy documents we should retain to meet our financial, legal, or tax
obligations, unless permitted by BD policy

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and shareholders

Safeguarding our reputation Authentic answers

What we believe
We all have to protect our reputation by being positive and truthful when Q I was at a trade show, and I was talking about our company
talking about our company. with someone who I thought was a possible customer. It turned out
she was a representative of a hedge fund that has invested in BD.
Why it matters I’m worried I did something wrong.
Since our founding, we have built and maintained our reputation and
trustworthiness. If we don’t use one voice and share one message, A If you kept to publicly available information, you’re fine.
But if you were talking about changes that aren’t public, that
it may hurt our company.
could be an issue. It’s important to remember that any discussion
Communication with the media and investors with an external source can be taken as an official statement.
People at trade shows may be reporters or analysts. You should
You should know that any discussion with someone outside our
company—including social media posts—can be taken as an official always ask for peoples’ names and affiliation before starting a
company statement. Our customers, investors, and communities deserve conversation, and never share nonpublic information with people
accurate, complete, and clear information about BD. We have a specially outside of BD. You should also be up to date with public information
trained group that’s authorized to speak on behalf of our company. if you’re talking with anyone outside the company.

How we do what is right

Do:
• Refer all external questions to Public Relations unless you know for
sure you’re authorized to answer
• Tell your manager or Public Relations if you come across any
information about our company or our products that’s wrong
Don’t:
• Share your opinion or divulge information about our company, our
customers, or our business partners

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and shareholders

Safeguarding our reputation (continued)

Responsible use of social media
We embrace the power of social media, but take care not to share
information or opinions that could hurt our company’s reputation.
Remember that online statements can be taken out of context, distorted,
or misunderstood.

How we do what is right

Do:
• Use social media in ways consistent with our values and policies
• Feel free to share any posts made from an official BD account
• Report any negative post about our company to Public Relations
• Be aware that your comments on social media could be copied by
others and shared, even if you delete them or they disappear
Don’t:
• Make negative or inaccurate remarks about BD
• Represent your personal views as those of BD
• Share confidential information, whether it’s ours or from our
customers, business partners, or competitors
• Engage in inflammatory online exchanges with anyone disparaging
the company or its products
• Make statements that could in any way be construed as a product
claim

Get more information:

Social Media Personal Associate Use Guidelines

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Contributing to our
communities. . . . . . . . . . . . . . . . . . . . 61
Respecting human rights. . . . . . . . . 63
Protecting the environment . . . . . . 64
Participating in the
political process. . . . . . . . . . . . . . . . . . . 65

We are passionate about advancing the world of healthTM. That passion

drives a strong commitment to promoting human health, protecting the
global environment, and improving the communities we serve. We work

Our world
to improve the communities where our patients and their caregivers live and
work. We are dedicated to preserving and protecting the environment. Being a
responsible global citizen leads to long-term, sustainable success for the company
and all of our stakeholders.
To learn more about how BD is making a difference in this area, please
visit www.bd.com/sustainability.

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Contributing to our communities

What we believe
We believe in supporting the communities where we live and work.
We also want to address broader healthcare challenges in society.
We encourage our associates to get involved in these efforts.

Why it matters
Our success depends on our reputation. In part, our reputation is formed
by what we do for our associates, patients, customers, communities, and
the world at large. And social investing is an important part of building
and maintaining our reputation for always advancing the world
of healthTM.

How we do what is right

Do:
• Support causes and non-profit organizations that are consistent with
our Purpose or that support health and well-being around the world
and in the communities in which our associates work and live
• Explore volunteer opportunities and charitable activities that enhance
engagement with your community, and those that help you better
understand and serve the needs of the most vulnerable populations,
locally and globally Get more information:
Global External Funding Policy
Don’t:
Social Investing site
• Force others to contribute to charitable organizations or other BD Matching Gift Program (for U.S. associates)
community activities Volunteer resources
Volunteer awards

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Contributing to our communities (continued)

Charitable contributions, grants, and donations
Authentic answers
We use our resources, time, and skills to help non-profit groups, such Q A BD customer asked me if we can help with a charitable trip
as those that seek to expand access to healthcare, advance human
they are planning. It would provide healthcare to patients who can’t
potential, and help vulnerable communities increase their resiliency.
afford it. A non-profit part of the customer’s organization would
How we do what is right manage the trip. They asked if BD can support the trip with

Do: free of charge products and a cash donation. Can we do it?

• Make contributions, grants, or donations to charitable, education, A We believe that supporting worthy charitable causes that help
or research organizations
improve healthcare is part of our Purpose, advancing the world of
• Encourage individuals or organizations requesting charitable or
healthTM. We may be able to support a charitable cause like this trip if
educational grants to follow our Global External Funding Policy
we follow our policies and procedures. Contact Social Investing or an
• Keep records of all contributions, grants, or donations
Ethics & Compliance representative for more information.
Don’t:
• Make contributions, grants, or donations to influence someone to buy,
lease, recommend, or prescribe our products
• Provide contributions, grants, or donations to individual healthcare
professionals (HCPs) or government officials (GOs) for any purpose
• Make a promise to make a contribution, grant, or donation on behalf
of our company unless you are authorized to do so

Get more information:

Global External Funding Policy

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Respecting human rights

Advancing your knowledge What we believe
To support human rights, we make the following We protect human rights in all areas of our business. We believe that all
people should be treated with dignity and respect, and we expect our
commitments in all we do.
business partners to do the same.
• We provide a safe and healthy workplace
• We do not use child labor Why it matters
• We do not use forced or indentured labor of any kind As a responsible global citizen, we believe in safeguarding human rights
• We do not allow discrimination in our hiring in everything we do. We never engage in human trafficking, forced labor,
child labor, or unsafe or unfair work practices.
• We do not allow abuse, harassment, or threats
• We support the freedom of association and the rights of workers How we do what is right
and employers to bargain collectively
Do:
• Follow our Global Human Rights Policy, which is based on the UN
Universal Declaration of Human Rights, and the laws that apply
• Help us keep working conditions safe and healthy and maintain fair
and proper compensation for all BD associates
• Make sure our suppliers are committed to proper labor and sustainable
sourcing practices that protect workers and communities (get the
details in our Expectations for Suppliers)
• Alert your supervisor or the Ethics Office when you see or suspect
human rights concerns

Get more information:

Global Human Rights Policy
Expectations for Suppliers

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Protecting the environment

What we believe
We believe in environmental responsibility and accountability. That’s
because we understand that environmental performance can have an
impact on human health.

Why it matters
Climate change and population growth are placing great demands
on natural resources and bringing new challenges to our business and
operations. Increasing regulatory requirements and customer expectations
require us to consider the environmental impact of our business and
minimize our environmental footprint.

How we do what is right

Do:
• Follow all environmental laws and BD policies and procedures
• Safely dispose of any hazardous waste and report any spills or leaks
• Look for ways to be more efficient and safeguard energy and
other resources
• Tell the Environment, Health and Safety department about any
environmental concern

Get more information:

Environment, Health and Safety policy
Sustainability and Climate Change Management reports

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Participating in the Advancing your knowledge

political process
How does BD engage in the political process?
What we believe
We have a team of public affairs professionals who work closely with
We believe in a system in which we are free to engage in the political country and business leaders to engage in policy discussions relevant
process. We participate in the political process ethically and transparently, to what we do. We only participate in advocacy activities that help
and we separate our personal political activities from our work at BD. our Purpose of advancing the world of healthTM, without being
influenced by the personal political affiliations or views of anyone
Why it matters working at BD.
We believe that an open political process makes for a fairer, more
efficient, and more productive society. We use our skills, knowledge, and We support regulatory and reimbursement framework that make
global reach to help advance public policy. sure medical technologies are safe and work well, while also giving
patients access to them in a timely manner. We also support sensible
How we do what is right tax and trade policies that improve competitiveness and innovation
and seek to promote a sustainable healthcare ecosystem.
Do:
• Talk to BD public affairs professionals to make sure you’re behaving We run a political action committee (PAC) in the United States.
ethically and legally when dealing with elected or appointed officials The BD PAC lets eligible U.S. associates voluntarily give their own
on behalf of the company money to candidates for elected office who share our position on
• Make it clear that your opinions are your own when taking part in public policy issues.
personal political activity
Don’t: Get more information:
• Use company money to support candidates, political parties, ballot Participation in the Political Process
measures, and referendum campaigns

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Conclusion
BD has built a reputation for quality and integrity that is the
foundation of our success. Maintaining this most valuable
asset is of the greatest importance to our continued progress,
and is a responsibility we all share.

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Our commitment Speaking up

Acting with integrity is critical to the company’s success and reputation. We encourage and expect all associates to speak up and report actual or
Our commitment extends beyond compliance with the law. We believe suspected violations of laws, the Code, BD policies, or relevant industry
that the best way to be a great company and to deliver value to codes. If you’re unsure about how to handle a specific situation, or if you
find any aspect of the Code unclear, there are a number of ways you can
our customers, associates, and shareholders is to be fair, honest,
ask questions, raise concerns, or seek guidance, such as:
and ethical in our business practices and behavior at work.

Using the online reporting tool at: www.bd.ethicspoint.com

Calling the Ethics Helpline—you can find the right local or international
number on Maxwell, our intranet site

Emailing the Ethics Office: [email protected]

Talking to your manager or a neutral and uninvolved manager

if you’d prefer

Contacting a representative in Ethics & Compliance, Human Resources,

AccessHR, Law Group, or Internal Audit

Accessing the ethics@work app on your mobile device to connect with

Ethics & Compliance resources anywhere, anytime

BD does not tolerate retaliation in any form and will always make every
reasonable effort to protect your confidentiality.

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Index
Contacts and Sites BD Trade Compliance Procedure Global Third-Party Intermediary Life Cycle
AccessHR BD Travel & Expense Policy Management Policy
Corporate Communications Claim substantiation HIPAA Privacy, Security, and Breach Notification
Rules – Policies and Procedures
Corporate Secretary Disease awareness communications
Insider Trading and Securities Transactions Policy
Corporate/Site Security Environment, Health and Safety policy
Internet-based platforms
Environment, Health and Safety Equal Employment Opportunity Statement
Ethics & Compliance Participation in the Political Process
Expectations for Suppliers
Ethics Helpline Presenting balanced product information in ad
GDPR Data Protection Policy prom materials
Ethics Office Global Advertising and Promotion Review, Product Complaint Form
Global Trade Approval and Escalation Process Product Security policy
Global Transparency Global Antibribery & Anticorruption Policy Promotion of RUO and IUO products
HROne Global Antitrust and Competition Law Policy Promotional distribution of publications
Human Resources
Global Conflicts of Interest Policy Social Media Personal Associate Use Guidelines
Internal Audit
Global Data Disclosure and Publication Policy Speaker programs and events
Law Group
Global External Funding Policy Sustainability and Climate Change
Online Reporting Tool
Global Free of Charge Products Policy Management reports
Privacy Office
Global Health Care Economic Information Trade Secret Policy
Public Relations
(HCEI) Policy Trade shows
Social Investing
Global Human Rights Policy Use of case studies and testimonials in ad
Sustainability prom materials
Global Human Subject Research Policy
Policies and Guidelines Global Investigator Sponsored Studies Policy Volunteer awards
BD Information Security Policy Global Policy on Advertising and Promotion Volunteer resources
BD Information Security Standards Global Privacy Policy Weapons in the Workplace Policy
BD Matching Gift Program (for U.S. associates) Global Speaking Up Policy Workplace Violence Policy
BD Procurement Purchasing Policy Global Standards for Interactions with HCPs,
BD Quality Policy HCOs, and Government Officials

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Becton, Dickinson and Company, 1 Becton Drive, Franklin Lakes, NJ 07417, U.S.
Phone: 201.847.6800

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