Standards

The Medtronic Code of Conduct defines what we consider to be appropriate behavior in our business interactions and covers all areas of professional conduct, including customer relationships, conflict of interest, insider trading, intellectual property, and confidential information.

Every employee is expected to adhere to the Medtronic Code of Conduct as a condition of employment and is required to bring any suspected violations to the attention of Medtronic management or the company’s human resources, ethics and compliance, or legal groups. Employees also have access to our Voice Your Concern confidential compliance hotline.

Medtronic also complies with standards adopted by medical device trade associations in the United States and Europe: the AdvaMed, Code of Ethics on Interactions with Healthcare Professionals and the EucoMed Guidelines on Interactions with Healthcare Professionals. The AdvaMed code was revised in 2009 with, among other measures, explicit prohibitions against providing entertainment and giving gifts. We revised our own U.S. Business Conduct Policy, to align our business practices with those set forth by AdvaMed. In addition, we have country-specific Business Conduct Standards that address the diverse legal and regulatory complexities in markets around the world.

Executive Conduct

Medtronic also has a Code of Business Conduct and Ethics for Members of the Board of Directors and a Code of Ethics for Senior Financial Officers. The latter outlines policies for our Chief Executive Officer, Chief Financial Officer, Treasurer, Controller, and other senior financial officers related to internal controls, the public disclosures of Medtronic, violations of securities laws or other laws, rules or regulations, and conflicts of interest. Individuals with concerns regarding executive conduct can share them with the Audit Committee.

Antitrust/Competition

Medtronic’s Code of Conduct requires that all employees compete fairly and honestly and comply with the antitrust and competition laws of all countries in which Medtronic does business. Employees must compete solely on the merits of our products, services and reputation, and managers are responsible for ensuring compliance with the Code.

Click for more information on Improper Payments, Fair Dealing, Antitrust/Competition, and Conflict of Interest Dealing.

Our Code of Business Conduct and Ethics for Members of the Board of Directors also addresses these issues as they relate specifically to the Board.