Governance, Ethics, and Integrity

MAINTAINING A CULTURE OF ETHICS

Our company’s continued success depends on maintaining relationships of mutual trust with our stakeholders. Trust is hard earned and easily lost. Over six decades, we have earned stakeholder trust by establishing policies and practices that support strong corporate governance and define ethical behavior.

Medtronic CEO, Omar Ishrak, and lead independent director, Scott Donnelly, coupled with a capable, engaged, and fiercely independent board of directors, set companywide expectations for strong corporate governance. Leadership guides our public policy advocacy and stakeholder engagement.

Our culture of ethics starts with leadership and is part of everyone’s day-to-day work. Every Medtronic employee plays a part in safeguarding our reputation by acting ethically and with integrity, including our sales and marketing teams. Our extensive training program ensures that these teams understand industry risks, know how to promote our products honestly and with transparency, and protect customer data security.

By adhering to our policies, our employees serve the best interest of our patients, earn stakeholder trust, meet regulatory requirements, and protect our reputation as a company committed to ethical business practices.

GOVERNANCE, ETHICS, AND INTEGRITY HIGHLIGHTS FROM FISCAL YEAR 2018

Our board of directors guides our corporate strategy and reviews and approves our annual strategic plan. Maintaining a mix of backgrounds and experience in our leadership is essential to understanding and reflecting the needs of our diverse stakeholders. Of our 12 board members, three are women and three represent ethnically diverse backgrounds.

We engage and educate employees on ethics in many ways, including through our Code of Conduct, annual review process, employee communications, Ethics Circles, and Ethics and Integrity Week. This year and every year:

We retrained employees on the Medtronic Code of Conduct and required everyone — including board members — to be certified.
Currently, more than 7,800 employees are part of one of our 150 Ethics Circle groups across 20 countries.

We put integrity at the core of our sales and marketing practices. Our extensive training program ensures employees understand industry risks and know how to promote our products honestly and with transparency. By adhering to our policies, our employees serve the best interest of our patients, earn stakeholder trust, meet regulatory requirements, and protect our reputation as a company committed to ethical business practices. In FY18:

Over 15,500 marketing and sales employees received training on ethical product promotion.
We reviewed 21,000 transactions for risks including bribery, kickbacks, and off-label product promotion as part of a comprehensive program put in place to help ensure that our marketing practices comply with internal policies and external regulations.

In FY17, we launched a Distributor Code of Conduct and embedded it in our annual training cycle. In FY18, 96% of our distributors received this training.