You are submitting information through the EthicsPoint online reporting system (the “EthicsPoint System”), a confidential reporting system provided by Stryker Corporation (“Stryker” or the “Company”).
The data privacy and protection regulations of some countries require that a person making a report containing personal information must be notified of certain collection and retention practices regarding information submitted through this system, as well as consent to certain terms and conditions regarding the information submitted by that person. If you do not wish to accept the terms below, we are unable to accept any information through this system and would ask that you please report this matter directly to your local management, Human Resources representative, Compliance representative or Legal representative.
Use of the EthicsPoint reporting site is entirely voluntary. You are encouraged to report possible violations directly to your any of the Stryker representatives outlined above, depending on the nature of the possible violation. If you feel that you are unable to do so, you may use the EthicsPoint System to make your report. In certain countries, Stryker may only accept reports through the EthicsPoint System that relate to financial, accounting, auditing or bribery matters. If your concern pertains to a matter that, under local law, may not be accepted by Stryker through the system, you will need to contact the appropriate local Stryker representative to report the matter.
Please be aware that the information you supply about yourself, your colleagues, or any aspect of the Company’s operations may result in decisions that affect others. We therefore ask you to provide only information that, to the best of your knowledge, is correct. You will not be sanctioned for submitting information in good faith. However, if you knowingly provide false or misleading information, it may result in disciplinary action. The information you submit will be treated confidentially. We encourage you to identify yourself so that we can follow up with questions we might have.
What Information is collected? On the EthicsPoint site, you may directly submit to the Company the following information: your name and contact details, any question you may have, the name and title of all individuals you may be reporting, and a description of any questionable conduct, including all relevant details.
How will the Information be used? All the information will be stored on the EthicsPoint database hosted by NAVEX in the United States of America (“NAVEX”). NAVEX is EU-U.S. Privacy Shield Framework certified. Unless required by law or litigation, the information in the EthicsPoint database may only be reviewed and used by those entitled individuals who need to know the data to fulfill their job duties. These individuals may include appropriate human resources, finance, audit, legal, security, management, or executive functions at the Company, employees within the Company’s Compliance Department, or technical staff at NAVEX. Those individuals may be located in the United States or in another country where the European Commission has not found that the privacy laws ensure the same level of protection of personal data as provided in the EU. In addition, all information you provide may be stored by the Company’s Compliance Department in the course of answering your question(s) or investigating the report.
The Company will evaluate the information you provide, and may conduct appropriate investigations, and take corrective action.
Note that all individuals you identify through EthicsPoint will in due course be informed about the fact that a report has been lodged. The information will not reveal your name or identity. In addition, all such individuals you identify will have the right to correct information reported by you.
Any information you submit that is not needed to answer your question or for the investigation of any incident will be deleted or archived if needed and as permitted by local law. In addition, once we have answered your question or any investigation is complete, all information submitted by you will be deleted or archived if needed and as permitted by local law. The Company will take adequate technical, organizational, and legal steps to secure the information you provide. It also requires NAVEX to adequately secure your personal data and not use it for any unauthorized purposes.
If you have any questions regarding the EthicsPoint System and Stryker’s practices with respect to the information submitted through the system, you may contact us at ethicshotline@stryker.com.