Ethics and Compliance

At Hospira, we are committed to making a difference with integrity and with high ethical standards in everything we do.

Acting with integrity allows us to earn and maintain the trust of everyone we work with, from our colleagues at Hospira and our partners at other companies to the patients and healthcare professionals whose lives we impact and the communities in which we live and work.

Hospira’s commitment to integrity is reflected in the following sections:

  1. OVERVIEW OF HOSPIRA’S ETHICS AND COMPLIANCE PROGRAM
  2. COMPLIANCE ELEMENTS FOR HOSPIRA EMPLOYEES, AGENTS AND CONTRACTORS
  3. COMPLIANCE ELEMENTS FOR HOSPIRA’S BUSINESS PARTNERS
  4. TRANSPARENCY AND DISCLOSURES

1. OVERVIEW OF HOSPIRA’S ETHICS AND COMPLIANCE PROGRAM 

Introduction
Hospira is committed to conducting business in a manner that is ethical and in compliance with applicable laws and other requirements. As a part of the company's ongoing efforts in the area of ethics and compliance, Hospira has adopted an ethics and compliance program ("Compliance Program") designed to ensure compliance with, and to prevent and detect violations of, applicable laws and other requirements.

Hospira’s Compliance Program includes the following seven elements:

Leadership and Structure
Hospira has an Office of Ethics & Compliance ("OEC") that serves as the focal point of the company's Compliance Program. The Chief Ethics and Compliance Officer leads the OEC and reports directly to the Chief Executive Officer of Hospira. The OEC provides regular reports to senior management and to the Board of Directors and various committees thereof on the status of the company's Compliance Program.

The company's senior management has established an Ethics & Compliance Steering Committee ("Steering Committee") that consists of the Chief Executive Officer, his direct reports and certain others including the Vice President, Internal Audit. The charter of the Steering Committee includes overseeing the Office of Ethics & Compliance and addressing significant ethics and compliance matters that arise in the company. The Steering Committee, which meets quarterly, helps establish the appropriate "tone at the top."

Written Standards
Hospira established and published its Code of Business Conduct ("Code") for all officers, employees, agents and contractors of Hospira and its subsidiaries and joint ventures worldwide. The Code provides Eight Principles of Integrity, which include, but are not limited to, complying with laws and regulations, promoting a culture of integrity in the workplace, proper use of assets, maintaining accurate books and records, avoiding conflicts of interest and acting with integrity in interactions with third parties (e.g., healthcare professionals).

Other policies and procedures for specific compliance areas are in place to reflect Hospira's culture, processes and requirements. Specifically included are Hospira's procedures relative to interactions with healthcare professionals/customers ("PICs"). PICs are based on legal requirements and guidance from the Department of Health & Human Services Office of Inspector General as well as applicable industry and professional codes of ethics.

Education and Training
Hospira recognizes that education and training is a key part of an effective compliance program. All employees and contractors receive training and certification on the Code as soon as they become employed by Hospira. Additional ethics and compliance education and training programs are provided on an ongoing basis as required by an individual's job responsibilities and by changes in the laws and company policies and procedures. Specifically with regard to interactions with healthcare professionals, Hospira provides training to employees and contractors focused on the types of interactions that they are likely to have with healthcare professionals.

Internal Lines of Communication
Hospira fosters open communication and dialogue between employees and management through a variety of mechanisms. Hospira maintains various policies that have been designed to provide employees and other stakeholders with a means to communicate with management. These policies address anonymous reporting, confidentiality, open-door policy and non-retaliation.

Employees, customers, suppliers, and other stakeholders are able to ask questions in a confidential manner about ethical or compliance issues or to report possible violations of the Code, applicable law or company policies or procedures, without fear of retaliation, and anonymously, if they so desire, by contacting the OEC directly at OEC@hospira.com or through the Global Ethics & Compliance Helpline (“Helpline”). Individuals may contact the Helpline (available 24-7) via toll-free telephone at 1-866-311-4632 or via a web-based reporting tool at www.Hospira.EthicsPoint.com.

Assessment
Hospira periodically assesses the risk of its operations and takes appropriate steps to design, implement or modify each element of the company Compliance Program to reduce the risk of improper or unethical behavior.

Auditing and Monitoring
Hospira's Compliance Program includes monitoring, auditing, and evaluation of employees’ compliance with the company's Code, PICs and other ethics and compliance policies and procedures. These efforts are conducted by the Office of Ethics & Compliance on its own or in cooperation with Internal Audit, Legal and/or other functions of Hospira.

Corrective and Preventative Action
Hospira's Compliance Program clearly establishes the fact that inappropriate conduct will be investigated and addressed. In matters where violations of law, Hospira's Code, PICs or other policies and procedures are identified, disciplinary, corrective and preventative action will be taken in order to address the violation and deter future violations.

Hospira's Compliance Program is reasonably designed to prevent and detect conduct that may be inconsistent with the Code and other applicable laws and other requirements. Notwithstanding the comprehensive nature of Hospira's Compliance Program, the company recognizes that no program can completely eliminate the possibility that an individual will engage in improper conduct. When any such improper conduct is reported or detected, Hospira will investigate the matter and address it promptly and responsibly with corrective action including, but not limited to, appropriate disciplinary measures.

Conclusion
Hospira is committed to conducting its business in a manner that is ethical and in compliance with applicable laws, Hospira’s Code and other requirements. The company recognizes that compliance can best be achieved by ongoing efforts to communicate Hospira's values, the Code and policies and procedures to company officers, employees, contractors and agents. Hospira is engaged in that continuous effort and will from time to time update this overview to reflect changes that are made in the Compliance Program.

2. COMPLIANCE ELEMENTS FOR HOSPIRA EMPLOYEES, AGENTS AND CONTRACTORS 

CODE OF BUSINESS CONDUCT
At Hospira, we make a difference with integrity, personal accountability and responsibility. Hospira's Code of Business Conduct (“Code”) serves as our ethical compass for making decisions on behalf of Hospira that support Hospira’s Vision, Values and Commitment. The Code applies to all employees, contractors, temporary workers and agents of Hospira worldwide. To view the Code, click here.

ANTI-BRIBERY COMPLIANCE PROGRAM
Hospira prides itself in doing business ethically. As part of our continuing efforts to maintain high standards, Hospira has developed an Anti-bribery Compliance Program. Hospira’s Anti-bribery Policy is one element of this program. This document contains Hospira’s requirements to ensure that business practices and interactions between Hospira and third parties are conducted ethically and in compliance with the Code and other applicable laws and regulations.

To view Hospira’s Anti-bribery Policy, click here.

3. COMPLIANCE ELEMENTS FOR HOSPIRA'S BUSINESS PARTNERS 

DISTRIBUTORS
Our distributors play a vital role in fulfilling Hospira’s value of integrity to customers, patients and other stakeholders. Hospira expects that all our distributors are committed to our same ethical business practices through the Hospira’s Distributor Code of Conduct and the Guide for appropriate interactions with healthcare professionals for Distributors.

To view the Distributor’s Code of Conduct, click here and the Guide, click here.

SUPPLIERS
Our suppliers play an essential role in meeting the needs of our customers and patients. Hospira encourages and expects that all our suppliers are committed to strong ethical standards and requires its suppliers to operate in accordance with the principles of the Hospira’s Supplier Code of Conduct, or an equivalent Code of Conduct.

To view the Supplier’s Code of Conduct, click here.

4. TRANSPARENCY AND DISCLOSURES 

OPEN PAYMENTS

Open Payments or Physician Payment Sunshine Act (also known as “Sunshine”) is part of the healthcare reform act which became law in the United States in 2010. This regulation is aimed at increasing transparency in relationships between industry and medical professionals.

This regulation requires manufacturers of a covered drug, device, biological or medical supply to report individual payments or transfers of value to U.S. physicians and teaching hospitals in amounts greater than $10 per instance or $100 in aggregate in a calendar year. Hospira began tracking this information on August 1, 2013, per the regulations. The data will be displayed in a publicly viewable database in September 2014.

Hospira supports the Open Payments regulation and its goals because we recognize that transparency inspires public trust and confidence. For additional information regarding Open Payments please click the following link: http://www.cms.gov/Regulations-and-Guidance/Legislation/National-Physician-Payment-Transparency-Program/index.html

CALIFORNIA ACT DECLARATION
Annual Compliance Declaration

This Declaration is made by Hospira, Inc. as of July 1, 2015, in accordance with the provisions of California Health & Safety Code §§ 119400 et seq., also known as CA S.B. 1765 ("California S.B. 1765").

The California S.B. 1765 states that pharmaceutical companies shall include in their compliance programs policies for compliance with the PhRMA Code of Ethics (PhRMA Code). Because Hospira has both pharmaceutical products and medical devices within its product portfolio, Hospira has implemented a set of policies and procedures that conform with the PhRMA Code and the AdvaMed Code of Ethics. In response to CA S.B. 1765, Hospira has established an annual spending limit for educational items or activities directed toward "individual medical and healthcare professionals" in California. This annual maximum limit is $3,000 per individual medical or healthcare professional. This annual maximum limit excludes payments made for legitimate professional services provided by a health care or medical professional such as consulting. This limit also excludes disposable items given to healthcare professionals intended for free distribution to patients, printed advertisements about Hospira products given to healthcare professionals, and financial support for continuing medical education forums and for health educational scholarships.

To the best of Hospira’s knowledge and belief and based on a good faith understanding of the applicable statutory requirements, Hospira is in compliance with our Compliance Program and with the requirements of the California S.B. 1765.

For information related to Hospira's Compliance Program, please contact Hospira's Office of Ethics & Compliance by any of the following means:

Email to OEC@Hospira.com
Hospira’s Global Ethics & Compliance Helpline (available 24-7) via toll-free phone (+1-866-311-4632) or via a web-based reporting tool (www.Hospira.EthicsPoint.com).

CALIFORNIA TRANSPARENCY IN SUPPLY CHAIN ACT
This Act requires certain manufacturers to disclose their efforts to eradicate slavery and human trafficking from their supply chains. Hospira supports the intent of this Act and is committed to conducting business in a legal and ethical manner. We expect our suppliers do so, as well. Our expectations are set forth in our Supplier Code of Conduct.

The Code addresses responsible business practices including compliance with environmental health and safety and labor laws. Hospira’s expectation is that its suppliers should treat all workers with dignity and respect. Suppliers shall be committed to non-discrimination, fair treatment, wages, benefits and working hours according to applicable law, and freely chosen employment.

MAINE CLINICAL TRIAL DISCLOSURE
For information about clinical trials conducted by Hospira, Inc., visit http://www.clinicaltrials.gov. This information is being provided in part to ensure compliance with the State of Maine's Clinical Trial Disclosure Law (LD 1618). The information contained on these sites is not intended to replace the advice of a healthcare professional. Only a physician can determine if a specific medicine is the correct treatment for a particular patient. Nothing on this Web site or the links contained herein should be construed as the giving of advice or the making of a recommendation, and this information should not be relied on as the basis for any decision or action. The information contained on this site and the site to which this site links is not intended to promote or otherwise commercialize (directly or indirectly) any off-label or unapproved uses of Hospira products.

The information on this Web site is not intended to be used by physicians for making prescribing decisions. When making prescribing decisions, physicians should always refer to the specific labeling information approved for the patient's country or region.

Links to third party Web sites are provided for convenience only. Hospira, Inc. does not express any opinion on the content of any third party Web sites and expressly disclaims any liability for all third party information and the use of it.