Baxter 2021 Corporate Responsibility Report 43 Cross-Cutting Commitments Corporate Responsibility Commitment Introduction 2030 Corporate Responsibility Goals Empower Our Patients Protect Our Planet Champion Our People and Communities Appendix Ethics and Compliance Third Party Program policy training offered in 18 languages ~97% of employees completed annual Code of Conduct training Performed 24 compliance audits for distributors globally At Baxter, we work to drive a culture of integrity and the highest ethical behavior. We prioritize following legal requirements, being honest and fair, keeping promises, encouraging questions and valuing discussion—always reinforcing the importance of personal accountability and integrity. Patients, doctors, customers, regulators, investors, communi- ties and our employees count on it. COMPANYWIDE ACCOUNTABILITY Baxter has compliance committees for each country or cluster of countries where we operate to further integrate ethics and compliance in strategic plans and day-to-day activities. To help ensure the local implementation of our global ethics and compliance program, the business lead of each country or cluster holds mandatory quarterly meetings to facilitate discussion among local leadership about key issues, challenges and risks in their area. This approach, in conjunction with enterprise-wide established codes, policies, trainings and monitoring and assessment practices, enables us to more effectively target specific needs and drive ownership of and responsi- bility for ethics and compliance worldwide. Continuous Improvement of the Ethics and Compliance Program Ethics and Compliance Helpline and Investigations Asssessments and Audits Monitoring and Data Analytics PROACTIVE: Design > Implement > Guide Third Party Due Diligence Training and Communication Governance and Leadership Policies and Procedures REACTIVE: Detect > Prevent > Learn Relevant Policies and Standards ` Baxter Code of Conduct ` Baxter Global Third Party Anticorruption Policy ` Baxter Global Interactions Policy ` AdvaMed Code of Ethics ` MedTech Europe Code of Ethical Business Practice ETHICS AND COMPLIANCE TRAINING All employees are required to complete Code of Conduct training annually. In 2021, approximately 97% of employees completed the training. In addition to this training, we conducted an employee engagement campaign to reinforce the importance of ethics and compliance. More than 17,000 email-enabled employ - ees received a questionnaire, asking them to indicate whether they had read and agreed to comply with the Baxter Code of Conduct and to affirm that they were aware of their responsibility to report any violations. Of those who received the questionnaire, more than 98% affirmed their commitment to these items. We developed a related communication campaign to reach those who did not receive the formal questionnaire. 1 Select employees also complete ethics and compliance online courses relevant to their jobs every other year on a rotational basis. These courses cover topics addressed in Baxter’s Global Interactions Policy and Third Party Program. Training for our Third Party Program policy is avail - able in 18 languages. In 2021, 10,300 employees took this training. We also offer training to all third parties through our due diligence processing tool. In 2021, we updated the training for third parties to reflect changes in our Global Interactions Policy. In addition to the anticorruption content covered by the Code of Conduct and Global Interactions Policy training, our sales force participates in business-led, interactive workshops/trainings related to ethical interactions with the medical community and government officials, including discussion of real-life scenarios. At Baxter, off-label promotion is strictly prohibited by policy. This prohibition is included in our annual training to the Sales organization. DRIVING A CULTURE OF ETHICS AND COMPLIANCE Cross-Cutting Commitments Corporate Responsibility Commitment Introduction 2030 Corporate Responsibility Goals Empower Our Patients Protect Our Planet Champion Our People and Communities Appendix