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Ethics and Compliance

Contents

About This Report

HSE Performance

Social Performance

Economic Performance

Looking Ahead

Smith & Nephew is committed to promoting an effective corporate programme and is one of the key cornerstones of the company’s commitment to the highest standards of corporate conduct and integrity.

The corporate compliance programme has been designed to act as a guideline for the business units to improve, where appropriate, their existing programmes and maintaining consistency across Smith & Nephew.

The purpose of the programme is to increase the likelihood of preventing, detecting and correcting violations of law or company policy. While the implementation of 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.

In 2007 the Group Company Secretary also became the Group Compliance Officer and a Group Compliance Director reporting to the Group Compliance Officer has now been appointed. Each business unit has its own compliance officer and compliance committee who supply regular reports to both the Group Compliance Officer and the Group Compliance Director. The Board receive a regular report from the Group Compliance Officer.

Each business unit has continued to develop policies and procedures to implement these policies, initially for the businesses in the US and plans are being developed to expand the coverage.

The policies include:

Federal Anti-Kickback Statute Compliance Policy;
AdvaMed Code of Ethics on Interactions with Healthcare Professionals;
Physician Consulting Request Procedures;
Off-Label Promotional Policy;
Behaviour in Operating Room Environments;
Awards, Grants and Donations Request Procedures.

Education and training procedures have been put in place to ensure that all employees are aware of and understand the policies and are kept up to date with changes. This is achieved by the use of the business units’ intranet sites and other media. All new employees receive the appropriate training on appointment.

Guidelines have been developed in the US to ensure that Smith & Nephew does not knowingly do business with persons and organisations that have been excluded or are ineligible to participate in Federal healthcare programmes and disciplinary procedures have been developed for employees who violate the law or the compliance programme.

In the US a third party “whistleblowing” telephone line has been installed to supplement the Group-wide whistleblowing policy, and all relevant calls on this line are investigated and reported to the board of the Company.

Business Integrity