Compliance Program Description

At C. R. Bard, Inc. ("BARD"), we are committed to the highest standards of ethical business practices and compliance with applicable laws and standards.  In support of that commitment, we maintain an active compliance program consistent with the seven elements of an effective Compliance Program outlined in the Office of Inspector General Compliance Program Guidance for Pharmaceutical Manufacturers ("OIG Guidance") and in the AdvaMed Code of Ethics on Interactions with Health Care Professionals ("AdvaMed Code"). 

BARD has developed and distributes written compliance policies, procedures, and practices that guide the conduct of our employees and the day-to-day operations of BARD and its subsidiaries.  These include BARD's Business Ethics Policy, as well as policies and procedures addressing applicable federal and state healthcare laws.

BARD's Chief Compliance Officer reports to the CEO and to the Board of Directors regularly on compliance issues.  A Compliance Team of experienced compliance attorneys is responsible for the ongoing implementation and administration of the Compliance Program.  BARD's Management Compliance Committee provides guidance, support and assistance with the continued implementation of its Compliance Program. 

Training, education and communication are essential components of our Compliance Program.  We conduct regular, effective education and training programs for BARD employees.  Our Compliance Program also includes regular communications aimed at reinforcing awareness of and attention to our legal and ethical obligations.

BARD maintains effective lines of communication with our employees, including the availability of a compliance telephone hotline (877-285-4158) for our employees to report complaints or ask questions.  The compliance hotline is available 24 hours a day, 7 days a week.  At BARD we do not tolerate retaliation against anyone raising compliance concerns.  Nonetheless, we recognize that in some cases employees may be more likely to raise such concerns if they can do so anonymously.  Therefore, calls to the compliance hotline cannot be traced and the system affords callers the opportunity to remain anonymous.

We utilize audits as well as other risk evaluation techniques to monitor compliance, identify problem areas and assist in the reduction of any identified problems.

BARD's policies and procedures also contain provisions aimed at preventing the employment or retention of individuals or entities excluded from participation in federal health care programs.

The primary purpose of the Compliance Program is to identify risk areas, develop appropriate policies and procedures, and educate and inform employees on those policies and procedures to further our commitment to the highest standards of ethical business practices.  Nonetheless, no compliance program can prevent all instances of noncompliance or misconduct.  As a result, our Compliance Program also includes policies and procedures for the investigation of identified instances of non-compliance or misconduct, including directions regarding the prompt and proper response to detected offenses. 

At BARD, our core values of Quality, Integrity, Service and Innovation all are related to, and dependant upon, attaining the highest levels of compliance and ethical behavior.  We are committed to conducting our business consistent with these core values.