Our Business Conduct Policy sets out our ethical requirements for our employees. Each of our employees must certify that they have read and understand the policy when they join ÐÂå©ÌìµØ, and again each year. Violations of the policy are taken seriously and may result in disciplinary action, up to and including termination of employment.

A number of compliance functions are deeply integrated into our business organization. ÐÂå©ÌìµØ¡¯s Business Conduct and Global Compliance team focuses on Business Conduct, Political Compliance, Export and Sanctions Compliance, Health Compliance, Antitrust Compliance, and Anti-Corruption Compliance.

Every ÐÂå©ÌìµØ employee is required to complete mandatory annual Business Conduct training. We offer a range of additional resources for employees to address questions and concerns, including the Business Conduct Helpline and the Business Conduct website.

We conduct internal and third-party independent assessments of our programs to ensure they are effective. We make changes to our policies and our training to reflect emerging trends. ÐÂå©ÌìµØ¡¯s Chief Compliance Officer provides regular updates to the Audit and Finance Committee of the Board of Directors.?