ATTENTION! This web page is hosted on EthicsPoint's secure servers and is not part of the Medtronic website or intranet.

Frequently Asked Questions

What is "voicing my concern"?

Voicing your concern is asking a legal, compliance, policy, or ethics question; raising a concern; or reporting wrongdoing or misconduct.

Other channels are available for reporting concerns that are not legal or policy violations – beginning with your manager or local Human Resources representative.

I know someone who reported a concern, but nothing ever happened to the person who committed the violation. Why should I put myself on the line?

People may not raise concerns because they believe "nothing will happen." Medtronic is committed to responding to employees who raise a good faith concern about a potential issue. To protect the privacy of those involved, however, we may not always be able to share the outcome of an investigation with employees. If you have reported a concern locally to management and feel the situation was not resolved, you should escalate the issue to higher management, contact the Office of Ethics & Compliance, or submit your report and concerns to the Voice Your Concern Line.

If you see, hear, or otherwise learn about improper conduct, you must speak up. This basic rule applies to everyone who works for, or on behalf of, Medtronic anywhere in the world. If you fail to report misconduct you know about, you are violating a key requirement of our Code of Conduct and may be subject to disciplinary action.

What if I want to remain anonymous?

Face-to-face discussions are often best, but there may be times when you may not feel comfortable talking to someone in person or you may prefer to remain anonymous.

The Voice Your Concern Line allows you to report your concerns anywhere, anytime, completely anonymously. When calling or reporting your concern through the web-based form to the Voice Your Concern Line, you are not required to provide your name or other information that might identify you. All calls and electronic web reports are caller/user-identification blocked, and because the website is hosted by a third-party, you do not need to have access to the Medtronic internal network to submit your report.

If you choose to remain anonymous, Medtronic may be limited in its investigation and response. Investigators have to know sufficient circumstances about the report and the specifics of the allegation for effective investigation and follow-up. Remaining anonymous may, in some cases, prevent the investigation from proceeding. Should you then choose to disclose your identity, Medtronic will handle all reports with discretion and strive to maintain your confidentiality.

Will you protect my confidentiality?

Medtronic will handle all reports with discretion and strive to maintain protect your confidentiality.

Investigators have to know sufficient circumstances about the report and the specifics of the allegation for effective investigation and follow-up. In some situations, your identity may become known during the course of the investigation. If this occurs, Medtronic will strive to keep your identity confidential and prevent any retaliation based upon the report.

Also, there may be times when Medtronic has a legal obligation to make information about reported compliance issues available to third parties. In these situations, your identity may become known during the course of the investigation. If this occurs, Medtronic will strive to keep your identity confidential and will not tolerate retaliation against anyone who raises a concern or reports suspected misconduct in "good faith."

What if voicing my concern results in retaliation?

Any employee who seeks advice, raises a concern, or reports suspected misconduct in "good faith" is doing the right thing. Medtronic will not tolerate retaliation against that person. Anyone who engages in retaliatory action will face discipline, which may include any form of discipline up to and including termination – regardless of that person's stature within the company.

If you believe that you or someone you know has been retaliated against for raising an ethical or compliance-related issue, immediately contact the Voice Your Concern Line; a business unit or geography's compliance leader; Medtronic legal counsel; a human resources representative; or Tom Schumacher, the Medtronic Chief Ethics & Compliance Officer.

When do I have an obligation to "voice my concern"?

Anytime you see, hear, or learn of potential misconduct, you must voice your concern as soon as possible. It’s also important that you speak up if you need advice about an ethics or compliance concern. Timely reports allow for early intervention and may stop a small issue from developing into a bigger problem.

Significant misconduct must be reported immediately. Significant misconduct is any situation which may:

  • be potentially illegal – for example, a possible violation of laws that prohibit fraud or kickbacks;
  • violate our Code of Conduct or Medtronic policies – for example, our Business Conduct Standards or Quality Policy;
  • expose Medtronic, its employees, officers, or directors to liability; or
  • damage Medtronic’s reputation.

You must voice your concern if you believe that you may have been involved in potential misconduct when doing something on behalf of Medtronic. All Medtronic employees and agents are expected to know and follow the laws and company policies that are applicable to their jobs.

You must voice your concern if you receive information about potential misconduct from another person. Sometimes managers learn about potential misconduct from their direct reports or employees hear about suspected misconduct from other sources. If you receive information about potential misconduct, you must voice your concern.

What are examples of compliance concerns that I'm required to report?

The types of concerns you’re required to report vary based on where you work for Medtronic. For most employees globally, the scope is broad.

For employees in the European Union, local law limits the types of issues that can be reported to:

  • accounting,
  • internal accounting controls,
  • auditing,
  • bribery, and
  • banking and financial crime.

For all other employees, the following are some examples of the types of issues you must report:

  • Benefits offered or given to a customer to encourage or reward the purchase of products (such as bribes or kickbacks)
  • Bribery or attempted bribery of government officials, customers, or others
  • Material misrepresentation within documents submitted to a government entity, particularly in applying for benefits from any government healthcare program
  • Medtronic promotion of products for unapproved (off-label) uses (not including routine product technical support when, in the interest of patient safety, a physician has determined to make an unapproved use of a Medtronic product)
  • Probable violations of criminal, civil, or administrative laws applicable to any U.S. federal healthcare program for which penalties or exclusion may be authorized
  • Any U.S. government investigation or legal proceeding alleging Medtronic has committed a crime or engaged in fraudulent activities
  • Any ineligibility of a Medtronic employee or someone acting on its behalf to work with U.S. federal government programs because of misconduct
  • Breaches of protection of personal identifying information (for example, patient personal health information)
  • Exchange of pricing or other proprietary information with competitors or other anti-competitive behavior
  • Misuse of Medtronic funds, including theft, fraud, or embezzlement
  • Inaccurate creation, reporting, or falsification of company business or financial records, or regulatory submissions
  • Intentional misstatement of accounting records
  • Improper booking/accounting of sales revenue or expenses
  • Falsification of expense reports (including intentional acts of omission)
  • Falsification of research, development, production, or product quality data
  • Violations of our Code of Conduct or stated company policies, including local Business Conduct Standards
  • Deliberate or willful attempts to circumvent company policies, procedures, or controls
  • Retaliation against any employee disclosing an ethics or compliance concern
  • Unsafe work practices
  • Workplace violence
  • Discrimination or sexual harassment
  • Any non-compliance with product quality requirements
  • Unauthorized disclosure of Medtronic intellectual property or confidential information
  • Undisclosed conflicts of interest between a Medtronic employee and a competitor, supplier, or customer
  • Receiving any kickback from a Medtronic supplier/vendor of products or services

What else is expected of me?

In addition to reporting potential misconduct, Medtronic expects that you will:

  • always encourage (and never discourage) others to voice their concerns;
  • be mindful to protect the rights and concerns of anyone accused of misconduct;
  • be truthful, candid, and cooperative during any internal inquiries; and
  • never retaliate against an employee or agent who makes a report.

May I just ask a question?

Yes. "Voicing your concern" also means asking questions when you are not sure what to do. If you are not certain of the proper course of action, ASK! Medtronic's Voice Your Concern Line is intended to provide information and guidance. Typically, you should first ask your manager, or, as appropriate, your local Human Resources representative, business unit or geography's compliance leader or Medtronic legal counsel. If you are uncomfortable doing so or are dissatisfied with the response you receive, or prefer to remain anonymous, submit a report with your question to the Office of Ethics & Compliance by using the Voice Your Concern Line.

What if I believe I might have been involved in conduct that violates the law or company policy?

All allegations will be reviewed and appropriately redressed, and we look at the facts of each incident to ensure fair treatment. This includes reviewing the reasons for a violation, the good faith of the people involved, and the timeliness of corrective action. Not reporting a violation once you become aware of it can be more serious than the violation itself. In many cases, standards are violated due to ignorance or mistake, not deliberate and or premeditated misconduct. If you believe you may have violated a law or policy, the best course of action is to raise the issue and get it resolved.

What data protections on compliance reports are in place for employees based in Europe?

National data protection legislations based on or inspired by the European Directive on the protection of personal data are in place in European Union (EU) member nations, candidate members of the EU, and a limited number of other countries. These legislations apply to the processing of personal data by the independent third party that operates the Voice Your Concern Line for concerns submitted via phone or web report, as well as by Medtronic personnel once the report has been transmitted.

Why is the Voice Your Concern Line managed outside of Medtronic?

As part of the Voice Your Concern Program, Medtronic provides an option to safely and confidentially raise concerns or ask questions when people are not comfortable doing so through our other internal reporting mechanisms or wish to remain anonymous. To achieve this, Medtronic partners with an independent third-party to provide secure and confidential telephone and web-based systems to make reports. Medtronic is one of many companies that use a third party for this service. The service is offered 24 hours a day and includes translators for more than 150 languages for callers who do not speak English or who are more comfortable using their first language to describe their concern or question.

What options and resources do I have for voicing my concern?

Where to raise a concern depends in some degree on the nature of the issue and the people involved. Typically, the best place to raise an issue is within your own department or business unit. In most cases, your manager, your local Human Resources representative, or your business unit/geography's management is closest to the issue and may be the best place to go for a quick response.

If you are uncomfortable reporting an issue within your business unit, or local reporting does not make sense based upon the nature of the issue or people involved, other options include:

I have documentation to support my concern. What should I do with it?

Documentation to support your concern can be submitted in a variety of ways depending on how you voice your concern. If you choose to speak to your manager, HR or a legal or compliance employee, discuss with them the best way to preserve your documentation. If you’re emailing the Office of Ethics & Compliance or the Board of Directors, you may attach documentation to your message. If you are using the Voice Your Concern Line web form to report your concern, there is an option to upload documentation when submitting a case. If you make a report to the Voice Your Concern Line by telephone or have documentation that cannot be uploaded, you should indicate in your report that you have documentation that you haven't included. The Medtronic employee handling the report will contact you about how to submit the information.

Will my report be investigated? How long does it take?

Medtronic takes all reports seriously. All reports are reviewed to determine how best to investigate and resolve the matter, based on the nature of the report. A person is never presumed to be "guilty" based on a report without further investigation to determine the facts of the matter. Based on the facts, Medtronic then determines the best course of action to resolve the matter.

Investigations times can vary based on the significance of the allegations, the scope of business operations affected, the number of people involved, and the amount of evidence needed. Some investigations are completed quickly; others can take weeks, months, or even longer. Each case is unique, but we use a consistent process. Regardless of how long an investigation lasts, Medtronic takes each allegation seriously and conducts a thorough investigation.

I submitted a report through the Voice Your Concern Line. How can I monitor the progress on my concern or question?

Whether you call the Voice Your Concern Line or submit a report through the web form, you will receive a report key and password. This lets you follow-up on the report, either by telephone or online, to monitor progress on your report and communicate with the investigators. If you have additional questions, comments or documentation, or the investigators request your additional follow-up or documentation, this feature enables that two-way communication to happen.

Will I be told about the details of an investigation or its outcome?

In most cases, you will be told whether your reported issue was investigated and whether it was resolved. If you report the concern anonymously using the Voice Your Concern Line, you will be able to check on the status by checking back by phone or online using your report key and password. You should know that there are legal and other restrictions on what type of information Medtronic is allowed to provide.

What will management do about my compliance concerns?

Each case is unique, but we use a consistent process. If we are unable to substantiate the allegations or concerns, we may determine that we do not need to take action. At the other end of the spectrum, we may need to self-report to the government. If the facts warrant, management will take corrective action to improve business systems or take disciplinary action against employees who have broken the law or violated company policy. Discipline may take a variety of forms up to and including termination. In some cases we may report matters to law enforcement authorities for possible prosecution.

Where can I go for more information?

The complete Voice Your Concern Policy, Medtronic Code of Conduct, Business Conduct Standards, and False Claims Awareness Information for Employees are available through the Medtronic Office of Ethics & Compliance intranet site at www.EthicsAndCompliance.medtronic.com.

Return to Main Page