Code of Conduct
WHY WE HAVE A CODE OF CONDUCT
TOPIC AREAS
AT AVANOS, IT IS OUR MISSION TO DELIVER CLINICALLY SUPERIOR BREAKTHROUGH MEDICAL DEVICE SOLUTIONS TO IMPROVE PATIENTS’ QUALITY OF LIFE. COMPLIANCE IS AT THE CORE OF HOW WE OPERATE AS A COMPANY, AND IS INTEGRAL TO OUR SUCCESS AS A PURE PLAY MEDICAL DEVICE COMPANY.
The Code cannot describe all laws, regulations or Avanos policies that apply to us or to a specific situation. Instead, the Code creates a framework of ethical standards within which all employees and contractors must operate. Those standards are often higher than the minimum legal obligations. The Code is an important reference guide to us as we strive to conduct our businesses in an ethical and appropriate manner.
In a rapidly changing world, where innovation is key to winning in the marketplace, we want our teams to be taking smart risks to win. At the same time, we are committed to our values and to doing the right thing.
Reading and understanding the Code of Conduct is an important first step in getting to know our culture and our expectations. Nothing is more fundamental to your success at Avanos than understanding and demonstrating the ethical standards explained in our Code.
THE CODE APPLIES TO ALL OF US
Each of us has the obligation to read and understand the Code of Conduct. The Code of Conduct applies to every Avanos employee and contractors around the world. The Code of Conduct also applies to members of the Board of Directors of Avanos. If a local custom, culture, or law sets a different standard than the Code, you should ask the Compliance or Legal Departments for guidance.
We are each responsible for our own compliance with the Code, to report suspected violations, and to cooperate in the Company’s investigation of potential violations.
SHARE YOUR CONCERNS WITHOUT FEAR
If you become aware of a Code of Conduct issue, there are many reasons that you might not want to tell anyone. You might not be sure it happened. You might be afraid to “cause trouble” or that someone will “get back” at you. You might think it is someone else’s responsibility.
But doing the right thing means speaking up. If you do not feel comfortable using your name, you can share your concern anonymously. People who come forward with concerns play an important role in maintaining our ethical workplace. You have a responsibility to share information so that the company can respond quickly and take appropriate action. One of the most important ways you can make a difference is by being aware of any unethical or illegal workplace activity and promptly reporting it
NON-RETALIATION POLICY
Our Company is committed to protecting the rights of those individuals who report Code of Conduct issues in good faith. Our Company will not retaliate against a person who:
- Reports what he or she believes is a violation of our Code, our policies, or the law
- Raises a compliance question or seeks advice about a particular business practice, decision or action.
- Cooperates in an investigation of a potential violation.
You cannot lose your job or your benefits, or be demoted, suspended, threatened, harassed, or discriminated against, for raising a Code of Conduct concern honestly or for truthfully participating in a Company investigation. The employees engaged as investigators of any violation are also protected by this non-retaliation policy.
REPORTING HONESTLY
Reporting honestly means that you have a good faith belief that the Code of Conduct has been violated even if an actual violation cannot be verified. Filing a report to retaliate against another individual, gain an advantage in a personal conflict, or to harass or intimidate does not constitute reporting honestly. Dishonest reporting under the Code of Conduct is in itself a violation of the Code of Conduct. If you believe someone is retaliating against you, please report it as you would a violation of the Code.
Q&A
Yes. The conduct established in the Code applies to all employees worldwide regardless of the location. If a local custom, culture, or law sets a different standard than the Code, you should ask the Compliance or Legal Departments for guidance.
No. You cannot get in trouble or hurt your team leader’s reputation simply by making a report. You will not be held responsible for reports made honestly, even if they turn out to be unfounded. Investigations are conducted in an objective, fair and confidential way to ensure that employees’ reputations are protected. All concerns about the Code and reports of retaliation will be fully investigated.
RESOURCES FOR ASKING QUESTIONS OR REPORTING CONCERNS
Reporting suspected violations of the Code of Conduct is critical so that the Company can properly determine if a problem exists that needs to be fixed. For that reason, we all have an obligation to report suspected violations of the Code of Conduct. If you have questions about the Code or you are aware of suspected violations, there are several resources available to you.
Your team leader
You may take your questions and concerns to your team leader. If you do not want to tell your team leader about your concern, or if you do not believe your team leader has taken appropriate action, you can also go to:
- Another team leader
- Any member of the Global Security team
- Email: [email protected]
- Phone: 470-448-5731
- Mail: Avanos Medical, Inc.
5405 Windward Parkway
Alpharetta, GA 30004 USA
Attention: Global Security Department - Any member of the Legal or Compliance Departments
You may contact any member of the Legal or Compliance Departments with whom you have worked. You may also contact the Avanos General Counsel’s office at:
Phone: 470-448-5354
Mail: Avanos Medical, Inc.
5405 Windward Parkway
Alpharetta, GA 30004 USA
Attention: Legal Department
Any member of the Human Resources Department
You may contact the Human Resource representative to your business unit or country.
Compliance and Ethics Helpline or Online Reporting
You may report anonymously. Note, in accordance with applicable laws, the Compliance and Ethics Helpline may not be available in certain countries.
Violations of Accounting Practices and Internal Controls
VIOLATIONS OF ACCOUNTING PRACTICES AND INTERNAL CONTROLS
The failure to comply with the Company’s accounting practices, internal accounting controls, or auditing practices could have severe consequences for Avanos and its shareholders. If you have concerns with respect to these matters, you should report your concerns to:
General Counsel
Phone: 470-448-5354
Mail: Avanos Medical, Inc.
5405 Windward Parkway
Alpharetta, GA 30004 USA
Attention: General Counsel
Chairman of the Audit Committee Mail: Avanos Medical, Inc.
5405 Windward Parkway
Alpharetta, GA 30004 USA
Attention: Corporate Secretary
Compliance and Ethics Helpline
Online Reporting
Q&A
The Code of Conduct cannot possibly answer every question or ethical situation. If something does not seem right to you, ask your team leader or one of the other people listed in this Resources section.
COMPLIANCE AND ETHICS HELPLINE AND ONLINE REPORTING
Ensure that everyone has the ability to report Code of Conduct concerns on an anonymous basis, Helpline Numbers and an Online System are available. Your information will be taken by an independent company staffed by professionals trained to handle Code of Conduct reports for many companies across the globe.
Available 24 hours a day, 365 days a year
Report in any language
Report anonymously
Obligations of Team Leaders and Others Receiving Reports of Potential Code Violations
OBLIGATIONS OF TEAM LEADERS AND OTHERS RECEIVING REPORTS OF POTENTIAL CODE VIOLATIONS
Team leaders and others who receive reports of potential Code violations play a very important role in upholding the Code of Conduct. Avanos encourages team members to talk to their team leaders about their concerns. Team leaders and others who receive reports of potential Code violations need to be prepared and know how to handle any Code of Conduct concerns or reports. Team leaders should:
- Make sure that you know and understand the Code, and model your behavior consistent with the Code.
- Act to stop violations of the Code or the law by team members.
- Let team members know that you are available to discuss their concerns.
- Take team members’ questions and concerns seriously.
Once a potential Code of Conduct violation is reported to you:
- Feel free to seek guidance before responding.
- Raise all concerns to the appropriate level and function in accordance with the Protocol for Escalation of Code of Conduct Issues (PDF)..
- Support team members who raise concerns honestly and treat them with respect.
- Never let team members feel that their concerns are being ignored.
- Ensure that no retaliation occurs against someone for reporting a suspected violation of the Code.
Violations of the Code
VIOLATIONS OF THE CODE
Violations of the Code of Conduct are serious offenses. Violating the Code, our policies or the law may result in disciplinary action all the way up to termination. It all depends on the type of violation and how severe it is. Where a violation of the Code is also a violation of the law, you may be subject to fines, penalties, criminal prosecution or other legal remedies imposed by a governmental agency or a court.
