Code of Conduct
FAQS
WHY WE HAVE A CODE OF CONDUCT
REPORTING HONESTLY
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.
VIOLATIONS OF ACCOUNTING PRACTICES
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.
CONDUCT WITH OUR TEAMS
DIVERSITY AND INCLUSION AND NON-DISCRIMINATION
Report It. All employees are entitled to a workplace where their co-workers and team leaders treat them with dignity and respect. You should report the matter to your Human Resource representative or by using the Compliance and Ethics Helpline, even though doing so may make you uncomfortable. See: Resources for Asking Questions or Reporting Concerns.
Report It. Avanos policy requires that employment decisions be made without regard to the gender of the candidate. If you feel you were treated unfairly, you should report your concern. See: Resources for Asking Questions or Reporting Concerns.
WORKPLACE SAFETY
Report it. Never compromise safety. No production goal, cost saving, time saving, or competitive advantage is worth an injury of any kind. Every employee has the right to refuse to do work reasonably perceived to be dangerous to personal health or safety. See: Resources for Asking Questions or Reporting Concerns.
RESPECTFUL WORKPLACE
No. If you tolerate your team member’s inappropriate behavior, you are giving the message that it is acceptable. Your team should behave the same way at a business dinner that they would behave in the office. You should counsel the team member on appropriate behavior.
Report the incident immediately. Avanos will not tolerate acts or threats of violence and will investigate all reports. You have a responsibility to act when you know of a threat or risk to any of our people. See: Resources for Asking Questions or Reporting Concerns.
CONDUCT WITH OTHERS
COMPETITION
No, you should end the conversation and contact the Compliance and Legal Departments immediately. You should always exercise caution if you find yourself in a meeting with a competitor because it can give the appearance of impropriety. If you do find yourself in such a meeting you should never talk about business topics like those you mention as that conversation may lead to an improper agreement, or the appearance of an improper agreement, on pricing. If pricing is raised leave the room immediately and contact the Compliance and Legal Departments immediately.
SAFETY OF OUR PRODUCTS
Stop and Report it. Never do anything that you believe could compromise the quality or safety of our products. No production goal or time saving measure is worth compromising the trust our customers and patients place in us. Stop what you are doing and contact your facility quality leader to determine whether the material is safe and meets our quality specifications. See: Resources for Asking Questions or Reporting Concerns.
COMPETITIVE INFORMATION
No. Obtaining information about a competitor by disguising your identity is never appropriate. Gath- ering information about competitors is a legitimate business activity when done lawfully and ethically. You should also consult with the Compliance or Legal Departments before meeting with a competitor, because any such interactions may raise anti-trust concerns.
It depends. If the documents contain confidential or proprietary information, you cannot use or share this with Avanos. Avanos expects all employees to honor confidentiality or nondisclosure agreements or other obligations of confidentiality to their previous employer. If you are unsure, tal to the Compliance or Legal Departments before accepting, using or sharing suspect information.
ENVIRONMENT
Report it to your team leader. If you are aware of any potential violation of law or company policies or procedures it is your responsibility to report it. The incident or condition will be investigated and, if necessary, corrected. See: Resources for Asking Questions or Reporting Concerns.
GIFTS, ENTERTAINMENT AND OTHER FAVORS
No. Both are wrong. You should not be offering expensive gifts to vendors and just because you have given ane expensive gift does not mean you can then accept a more expensive gift.
It depends. Accepting lunch invitations is okay if you are meeting for a business purpose, but frequent or extravagant meals can appear to create a conflict of interest. Consult your team leader if a vendor constantly invites you to lunch. Tell the vendor about the Code and only have occasional lunch meetings with vendors.
No. Never accept items from Avanos vendors for personal use.
GIFTS, ENTERTAINMENT AND OTHER FAVORS TO GOVERNMENT OFFICIALS
A government official is anyone employed by any government or government-controlled enterprise or political party, such as officers, environment and health inspectors, customs officers, postal workers, members of a legislative body, or employees of government-owned hospitals.
No. Laws of most countries prohibit making payments of this nature and the Company forbids making these payments in any country.
You should immediately contact the Compliance or Legal departments. Under the U.S. Foreign Corrupt Practices Act and similar global anti-bribery laws, the Company can be held responsible for the actions of its distributors, which means that our distributors cannot do what we ourselves cannot do. Our Policy on Interactions with Healthcare Professionals (PDF) applies to all interactions with healthcare professionals, and our Policy on Anti-Corruption (PDF) applies to all interactions with government entities, including government hospitals.
No. Laws of most countries prohibit such payments under any circumstance, and the Company forbids making such payments in any country.
DOING BUSINESS INTERNATIONALLY
It depends. Consult with the Compliance or Legal Departments. If the database containing consumer information is going to be shared with the service provider in a different country, there may be data privacy issues. Different countries/ regions have different regulatory structures for ensuring that the privacy of personal information is maintained. In some countries, we could be in violation of privacy regulations by exporting consumer data from one country to another.
CONDUCT WITH OUR COMPANY
CONFLICTS OF INTEREST
No. Investing in an Avanos vendor is a conflict of interest and disclosing your interest does not remove the conflict.
Do not disclose any confidential information when presenting to outsiders. Do not accept payment of expenses if it could cause a conflict of interest, such as the vendor gaining favorable treatment from Avanos.
It depends. Your brother may approach Avanos to offer his services as long as you have no responsibility for procuring these services, and you have no involvement in the selection process. His company will need to go through the established selection process and meet Avanos criteria. You should tell your team leader about such situations.
It depends. There is a clear conflict of interest here which may be damaging to Avanos. You should seek further guidance from the Legal Department.
CONFIDENTIAL INFORMATION
Be careful. Media tools such as blogs, wikis and networking sites are subject to the same rules as any other communications. Do not disclose any confidential business information. For example do not write about acquisitions, product recalls, organizational changes, relationships with customers or vendors, financial information, personal employee information, (address, phone numbers, employee identification numbers), or any other sensitive or confidential information.
Be careful. Before placing confidential information on a Sharepoint site it is your responsibility to make sure that access is restricted so that it can only be viewed by the project team and other authorized personnel. If you are ever able to access information on a Sharepoint site that you believe should be restricted, you should immediately notify the Legal Department.
RECORD RETENTION
No. We all have a duty to dispose of records such as emails when they are no longer required to be kept by law or by our record retention schedules.
FINANCIAL REPORTING
No. You must record expenses in the proper accounting period. Charge activities to the year in which they occur. If you need to prepay this year for an activity occurring next year, contact your local finance team to record the item as a prepaid expense.
Report It. You should report the actual hours that you work at all times in accordance with local policies, law, and collective bargaining agreements. If your team is working overtime, you should report that overtime accurately. If you are not approved to work overtime, you should stop working when your shift is complete. Never work “off the clock” hours. See: Resources for Asking Questions or Reporting Concerns.
No. Create the purchase order for the $40,000 and obtain the necessary approvals. If you are uncomfortable challenging your team leader, report it to the Compliance Department or the Compliance and Ethics Helpline. See:Resources for Asking Questions or Reporting
Concerns.
FRAUD PREVENTION
Don’t do it. This can impact our financial results and is considered fraud. Discuss it with your
team leader so they know the difficulties you are facing with this customer.
No. We all make mistakes. Just make sure you indicate this in your next expense report and provide payment to cover the charges. However, if this is a habitual problem, there may be disciplinary actions.