Smith & Nephew is committed to a culture of performance, innovation and trust.  One of the ways we build trust with our patients, our stakeholders and the public is through our Global Compliance Programme. 
This programme helps to ensure that our Company maintains a strong reputation for integrity and ethical conduct and that our name and products are trusted everywhere around the world.

The purpose of the programme is to increase the likelihood of preventing, detecting and correcting violations of law or company policy.  While the programme does not guarantee that improper conduct will be entirely eliminated, it is the Company’s expectation that employees and distributors will abide by it.

Smith & Nephew has a Chief Compliance Officer who reports directly to our CEO and who delivers quarterly reports to the Board Ethics and Compliance Committee.  We also have designated Compliance Officers in each Global Business Unit, and have appointed a Vice President of Compliance for International and Emerging Markets. 

The Code of Conduct and Business Principles is the foundation of our Global Compliance Programme.  Our Code includes key provisions that guide our employees and agents, including prohibitions on improper payments and direction on appropriate interactions with healthcare professionals and government officials.  Our Code is supported by global policies and procedures, which are supported by local policies and procedures, as required. 

Our Code and policies align to key laws and industry codes, including:

• UK Bribery Act (2010)
• US Foreign Corrupt Practices Act (FCPA)
• Laws adopted pursuant to the OECD Convention on Combating Bribery
• US Federal Anti-Kickback Statute
• AdvaMed Code of Ethics on Interactions with Healthcare Professionals
• Eucomed Guidelines on Interactions with Healthcare Professionals

Employees are trained on our Code of Conduct as new hires.  We provide more targeted training for employees, contractors and agents, based on their function.  This training may include:

• Anti-bribery
• Off-label promotion
• Arrangements with healthcare professionals

In most countries (depending on local laws and regulations), we offer an “Integrity Line” where individuals can report a concern via the phone or a website.  The Company investigates reports received, and individuals found to have violated our policies may be subject to disciplinary action, up to and including termination.  We also make sure no action is taken against anyone who reports, in good faith, actual or suspected misconduct.