Code of Business Conduct

II. Decision-Making; Operation of the Code

Core Values

The world of business grows more and more complex and fast–paced, and it is harder to make good decisions and take the right actions. But Abbott’s long–term success clearly depends upon the choices we make every day. Therefore, it is critical that we all understand and meet Abbott’s expectations as to the way we behave in our business at all times.

First, we must base our decisions and actions on our core values of honesty, fairness and integrity.

• We will not tolerate fraud, deceit or concealment.
• Our decisions must be based on fact and fairness, not bias or prejudice.
• Our decisions must be based on strict principles of right and wrong as defined by the Principles set forth in this Code.

Compliance with Code

Second, we all must comply with this Code, which is intended to support us in making good decisions and taking the right actions, to help keep us from doing the wrong thing, and to help us comply with the laws, rules and regulations that apply to our business.

• We are all expected to understand how this Code applies to our own jobs and business decisions and activities – or if we don’t understand, we must get help with our questions. (The Disclosure Program indicates where to go with questions or concerns.)
• All persons covered by this Code are expected to demonstrate integrity and leadership by complying with the Code themselves, and promoting compliance by others.
• Promotion of, and adherence to, this Code are elements in evaluating the performance of everyone to whom this Code applies.

Abbott contract workers and agents (for example, consultants, contract sales forces, speakers, distributors, clinical investigators, etc.) must also comply with the applicable Principles of this Code. That is why, whenever we enter into a new contract or personal service agreement with a contract worker or agent, or whenever we renew or extend an existing contract or agreement, we must include appropriate compliance provisions. (Work with the Abbott Legal Division and Abbott Purchasing to make sure the appropriate provisions are included.)

 

Disclosure Program

Third, Abbott recognizes that many decisions are not easy. So, any time we have a difficult decision to make, or we don’t understand how the Code applies in a particular case, we should ask for advice and guidance. If we become aware of any violations or potential violations of the Code, or if we have complaints or concerns regarding accounting, internal accounting controls, or auditing matters, we must promptly notify the appropriate persons as indicated in Disclosure Program contact information.

• For any questions or concerns about interpreting or applying this Code, or any related Abbott standard, policy or procedure, contact:

	1.	Your manager;
	2.	Another manager;
	3.	A Human Resources representative;
	4.	An attorney in the Legal Division;
	5.	Your Division’s Divisional Ethics and Compliance Officer;
	6.	The Vice President and Chief Ethics and Compliance Officer, or the Divisional Vice President, Ethics and Compliance; or
	7.	The Ethics and Compliance Helpline (see contact information).

 

• To contact the Vice President and Chief Ethics and Compliance Officer, who manages the Office of Ethics and Compliance (“OEC”):

Telephone: 1-847-937-5210
Fax: 1-847-935-3939
E-mail: OEC@abbott.com

Address written communications to the Vice President and Chief Ethics and Compliance Officer, other than faxes and e–mails, to:

Vice President and Chief Ethics and Compliance Officer
Abbott Laboratories, Dept. 036X, Bldg. AP6A/1
100 Abbott Park Road
Abbott Park, Illinois 60064–6008, USA

Clearly mark the envelope with the following phrase:
“CONFIDENTIAL – TO BE OPENED BY THE VICE PRESIDENT
AND CHIEF ETHICS AND COMPLIANCE OFFICER”.

Mark e–mails “CONFIDENTIAL”

 

• The Ethics and Compliance Helpline is available 24 hours a day, 7 days a week. Calls to the Helpline may be made anonymously. To access the Helpline:

	1.	From the United States, Puerto Rico or Canada, dial 1–866–384–2756.
	2.	In all other countries, contact the local AT&T USA Direct Operator and then dial or request the operator to dial 1–866–384–2756.

If you have any problems with the toll–free number, place a collect call to 1–847–937–5210.

 

• Anyone who becomes aware of a violation, or potential violation, of this Code or any related Abbott standard, policy or procedure, must promptly notify the Office of Ethics and Compliance, either directly or through one of the contact alternatives listed in Disclosure Program. Such notification may be made anonymously. Any reports or concerns are kept confidential to the extent possible while still allowing Abbott to investigate and take appropriate action.
  
  
• Anyone who has a complaint or concern regarding accounting, internal accounting controls, or auditing matters must promptly notify Internal Audit or the Office of Ethics and Compliance.
  
  
• Abbott will not tolerate retaliation against anyone who makes a good faith report regarding a violation or potential violation of the Code.
  
  
• See Part VIII of this Code (“Accountability for Adherence to the Code”) for more information on how Abbott handles reports of violations or potential violations of the Code.