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Main Page Code of Conduct Frequently Asked Questions

Q. Why do we have an Ethics & Compliance Helpline?

We believe that you are our most important asset in ensuring that we are compliant with all applicable laws and regulations, as well as Company policies and procedures. We want to provide you with the ability to contact us 24 hours a day, seven days a week, in your local language, either by telephone or through the Internet. Violation of laws, compliance requirements, and Baxter policies is unacceptable at any level of our Company. Your input is imperative to help us protect our Company’s reputation and financial strength, and by giving you the option to report by phone or through the Internet, the Ethics & Compliance Helpline ensures that you can seek advice or raise a concern in the manner most comfortable and convenient to you.

Q. Does management really want me to report?

We certainly do. In fact, employees are required to report actual or perceived violations of law or Company policy. You know what is going on in our Company - both good and bad. You may have knowledge of an activity that could be cause for concern. Your reporting can help minimize the potential negative impact on the Company and our people. You also may help identify issues that can improve our corporate culture and performance.

Q. If I see a violation, can I report it to my manager, to Human Resources, or to an appropriate functional manager?

You certainly may. We encourage employees, as a first step, to reach out to their local management or other local resources for assistance in handling their concerns. Alternative means of reporting concerns, including the Ethics & Compliance Helpline, are always available.

Q. I am not 100% sure if my concern is valid or whether the conduct at issue constitutes a violation of the law or company policy. Should I still report it?

Yes. If you see, hear, or experience something that is suspicious or concerning, please report it. The Company can only do the right thing if concerns are brought to our attention and properly investigated. Even if a concern is determined to be unsubstantiated as a result of an investigation, we would rather you speak up, in good faith, about a potentially unethical situation, rather than ignore it.

Q. Where do these reports go?

Once reports are entered into the Ethics & Compliance Helpline, they are routed directly to members of the Ethics & Compliance Investigations team, which is a team within Baxter’s Ethics & Compliance department responsible for the triage of reports made through Baxter’s global reporting channels, including reports submitted to the Ethics & Compliance Helpline.

Q. Can I report anonymously?

Yes. Unless specifically prohibited by law, you have the right to report an issue anonymously through the Ethics & Compliance Helpline. However, we encourage you to provide some form of contact information, as you will contribute to the investigation by providing Baxter with the opportunity to follow up with you directly as needed.

Q. If I don’t report anonymously, will my personal information be shared with anyone?

Baxter respects and protects your privacy by treating your personal information with confidentiality and in accordance with applicable laws. Reported information, including your identity, will be kept confidential to the extent possible. Generally, Baxter will only disclose to stakeholders the information necessary to conduct and close an investigation and implement remediation actions. If you wish to learn more about how your personal information is processed by Baxter when you file a report through the Ethics & Compliance Helpline, please review the E&C Reporting Privacy Notice available here.

Q. What if I face retaliation for reporting or for speaking with investigators?

Baxter strictly prohibits any adverse conduct taken against you because you, in good faith, raised a concern or participated in an investigation. The Company enforces this prohibition of retaliation to encourage open communication and to create a culture where you feel safe to ask questions or raise concerns. If you believe you have faced retaliation of any kind, please report that to the investigator handling your report or via the Ethics & Compliance Helpline.

Q. I do not work at Baxter. Can I report a concern?

Yes, we welcome reports from external parties. If your concern is business-related, rather than relating to violations of law or our Company policies, it would more appropriately be directed to your business contacts within the Company rather than the Ethics & Compliance Helpline.

Q. Why should I report what I know? What’s in it for me?

We all have the right to work in a positive environment, and integrity is a core company value that helps maintain a positive work environment. You are accountable for acting in an ethical manner and letting the appropriate people know if someone is not acting ethically or compliantly. By working together, we ensure that we maintain a healthy and productive environment and achieve our results with integrity.

Q. Is there a restriction on how much information I can include in my report?

You are free to share any information that is related to the concern you wish to report. Baxter will rely on this information in its investigation. However, we ask that you avoid sharing information that is not related to your report, and that you do not disclose personal information about you or other people that is not relevant to your report. Particular attention should be placed on any sensitive information, such as, for example, information related to health, religious beliefs, sexual orientation, or criminal records, as that information should not be provided to Baxter unless it is necessary for the investigation of the report.

Q. If I report an issue online, can you identify me through my IP address?

If you choose to file the report anonymously, we respect your desire to remain anonymous and we do not undertake any efforts to identify anonymous reporters using IP addresses. NAVEX, which owns and operates the EthicsPoint website and platform, strips away IP addresses so anonymity is maintained.

Q. Can I still file a report if I don’t have access to the Internet?

You can file an Ethics & Compliance Helpline report from any computer that can access the Internet. You can file from home or from your mobile phone. Many public locations, including public libraries, have Internet-connected computers. If you don’t have access to or are uncomfortable using a computer, you can call the toll-free Ethics & Compliance Helpline that is available 24 hours a day, 365 days a year, in your local language. Refer to the “Make a Report” section on the home page of this site for a local toll-free number.

Q. Is the telephone option of the Ethics & Compliance Helpline system also confidential and anonymous?

Yes. You will be asked to provide the same information that you would provide in an Internet-based report, and an interviewer will type your responses into the Ethics & Compliance Helpline. If you wish to remain anonymous, you can choose to do so. Reports submitted over the phone have the same security and confidentiality measures applied to them as the Internet reports.

Q. What if I remember something important after I file the report? Or what if the company has further questions for me?

When you file a report through the Ethics & Compliance Helpline, you receive a unique Report Key and are asked to choose a password. You can return to the Ethics & Compliance Helpline again, either by Internet or telephone, and access the original report to add further information that would help resolve the open issues or to ask or answer questions posed by an investigator.

Q. What is EthicsPoint®?

EthicsPoint® is our Helpline tool and website, provided by Baxter’s third-party provider, NAVEX. Many companies worldwide use EthicsPoint as their Internet and telephone-based reporting tool that helps Company management and employees work together to address complaints regarding ethics and compliance concerns.