Global Third Party Anticorruption Policy

Baxter is committed to conducting business with integrity and in compliance with the law in all countries in which we operate. The U.S. Foreign Corrupt Practices Act, UK Bribery Act, and many local country laws prohibit improper payments and provision of improper benefits to Government Officials. It is critical that all Third Parties who interact with Government Officials, Healthcare Professionals, Medical Institutions and Non-Profit Organizations on Baxter’s behalf share our commitment to conducting business with integrity and in compliance with the law.  The Third Party Policy expands on the prohibitions of our Code of Conduct and Global Interactions Policy against corrupt payments through Third Parties and ensures a consistent process for the selection, retention and monitoring of Third Parties that perform certain services and activities for Baxter.

What is a Third Party under this Policy?

A Third Party, as defined by this Policy, includes but is not limited to any party that interacts with the Non-U.S. medical community or Government Officials on Baxter’s behalf.  A Third Party may be engaged in any of the following activities, for example:

1. Markets or promotes Baxter products;
2. Negotiates or executes Baxter agreements;
3. Lobbies or advocates for Baxter;
4. Provides regulatory consulting services;
5. Provides customs clearance services;
6. Remunerates or provides other benefits, such as congress registration, travel or accommodation, to Healthcare Professionals on Baxter’s behalf.

Before Engaging a New Third Party

To ensure that we deal with reputable and qualified Third Parties, Baxter must exercise proper due diligence before engaging a new Third Party, which may include submission of a due diligence questionnaire, completion of an online training module and other due diligence and review processes as deemed necessary by Baxter.  We will communicate Baxter’s compliance expectations to every Third Party.

After Engaging a New Third Party

All agreements with a Third Party must contain our standard compliance clauses related to anti-corruption, accurate books and records provisions, audit rights, use of Sub Third Parties, and termination and other compliance representation and warranties. As with all vendors, all agreements with Third Parties must also include the Ethics & Compliance Standards for Baxter’s Suppliers. 

The due diligence process for every Third Party will undergo a periodic relationship during the term of engagement with Baxter.

Monitoring of Third Parties

Baxter will monitor our relationship with Third Parties for any changes that may necessitate action on its part or immediate refresh of the due diligence process.

This is a public version of Baxter’s Global Third Party Anticorruption Policy which has been condensed to ensure compliance with Data privacy laws and to prevent disclosure of sensitive information.