79 2021 ESG Report Healthy workforce and communities Appendices Responsible supply chain Product impact Climate change Introduction Transparency Ethics and compliance We are committed to a strong ethics and compliance culture. We do not tolerate actions or behaviors that violate the BD Code of Conduct or applicable laws and regulations. All BD associates are responsible for reinforcing our ethics and compliance culture and sustaining our reputation as a company dedicated to quality and integrity. We encourage and expect everyone at BD to speak up by asking questions, raising concerns, seeking guidance and reporting actual or suspected violations of laws, our Code of Conduct, our policies or our high ethical standards. This requirement extends to all associates, vendors and other third parties working on our behalf. Our BD Values further strengthen our culture of ethics and compliance and guide how we hold ourselves accountable to our shareholders and stakeholders. These values are cascaded through all levels of the organization. Read more about our commitment to ethics and compliance on our website . Code of Conduct The BD Code of Conduct sets the foundation for how we behave at BD. Our value “We do what is right” is the cornerstone of our Code. To do what is right, we follow the laws, rules and company policies that apply to us. We also follow the highest ethical standards, even when there’s no specific law or policy. Our Code provides guidance and resources to help us follow through on these ethical standards and protect our reputation. Everyone at BD—from directors to officers and associates—must follow our Code. It applies equally to everyone, no matter their position or level. BD associates receive information and training about the Code and other policies in several ways, including periodic communications and annual trainings. Associates can access detailed information on our expectations through our intranet and on our ethics and compliance mobile app. Our Code of Conduct is also available on our website . Under the oversight of the Audit Committee of the Board, BD’s global ethics and compliance function seeks to ensure that BD has a comprehensive compliance program that is designed to prevent and detect wrongdoing and continuously encourages lawful and ethical conduct. BD’s Senior Vice President, Deputy General Counsel and Chief Ethics & Compliance Officer leads the global ethics and compliance function and along with the BD Ethics and Compliance Committee, which comprises of members of BD’s Executive Leadership team, oversee these activities to ensure effective operation and enforcement of BD’s global ethics and compliance program. The program is integrated into our global business operations. We evaluate the effectiveness of our program and adapt it periodically to ensure that it is appropriately tailored to address the risks inherent in our global business. Reporting ethics concerns Except as prohibited by applicable law, BD associates are obligated to report any suspected violations of laws, industry codes, the BD Code of Conduct or BD policies in accordance with the BD Global Speaking Up Policy. BD takes all reports of violations of laws, BD policies and ethical standards seriously and will promptly, fairly and thoroughly investigate all such reports. BD does not tolerate any form of retaliation against any person who in good faith reports an actual or suspected violation. BD is committed to creating an environment in which all associates feel comfortable raising concerns, seeking guidance or asking questions without fear of retaliation or discipline. Anyone can seek guidance or report ethics concerns in a number of ways, including the BD Ethics Helpline or via email . The Helpline is independently operated and available anywhere in the world 24 hours a day, 7 days a week. The Helpline can be reached by telephone or online . The Helpline provides translation services as needed, and reports can be made anonymously where permitted by law. BD associates can also report violations to their supervisor, management, Human Resources or the Law Group, or directly to Ethics & Compliance. In FY 2021, BD’s Ethics Office received more than 850 contacts from associates worldwide seeking guidance or reporting concerns. When an investigation has a finding, we may take corrective action, such as discipline up to and including termination of employment or providing nondisciplinary-based training and process improvements in areas where a gap has been identified. Antibribery and anticorruption BD does not engage a third-party intermediary to do anything BD or its associates are prohibited from doing. The central Ethics and Compliance team provides resources to regional and local country management to enhance their anticorruption and compliance business practices. This includes incorporating compliance requirements into existing business practices and advising local management on anticorruption compliance-related issues. A key focus for BD is driving compliance in our third-party intermediary networks across the globe, resulting in stronger business relationships while upholding our reputation. These efforts are advanced by fostering collaboration with business leaders to deliver consistent and clear policies and approval processes—along with enhanced third-party life-cycle management procedures—to help provide assurance that BD is “doing business the right way.” BD is committed to training all associates via both in-person, scenario-based sessions and learning management system courses that leverage policy materials, such as the Global Antibribery & Anticorruption Policy and the Global Standards for Interactions with Healthcare Professionals, Healthcare Organizations and Government Officials. Risk-based training with third-party intermediaries is a core component of the Antibribery and Anticorruption program. These sessions are focused on applicable antibribery and anticorruption laws, including the Foreign Corrupt Practices Act and relevant BD policies. Associates are required to complete this training once every 18 months.