We take pride in our long history of serving the clinical needs of our customers and the patients who use our products. BARD's Mission reflects our shared commitment to them and to our shareholders, employees and community:
 

STANDARDS OF CONDUCT AND BUSINESS ETHICS

Compliance with Law and Government Regulations

At BARD, all employees, officers and directors must follow the highest ethical standards in every area of our business and in all of our daily activities and comply with all laws and regulations that apply to the conduct of the Company's business worldwide.

Product Quality, Drug and Device Laws

We are committed to providing our customers and the patients we serve with safe, effective, quality products that meet their needs and advance the delivery of patient care. We are proud to be employed in the business of serving the healthcare needs of patients and advancing medical knowledge and technology. We strive to find innovative solutions to the needs of customers and patients and to provide excellent service to all our customers.  We must comply with all applicable product regulatory requirements worldwide in all aspects of our business activities. 

At BARD, product quality is the business of every employee, and we encourage all employees to report all significant product regulatory compliance issues or concerns to the Regulatory Sciences Department, the Law Department, or BARD management.

Respect for Individuals and for Our Communities

Fair Employment and Business Practices, Respect for Others
We treat each other and our customers, vendors and other business partners and our competitors with respect, courtesy and fairness and comport ourselves in a professional manner. We do not take unfair advantage of anyone through manipulation, concealment, abuse of privileged or confidential information, material misrepresentation or other unfair dealing practice. We provide a respectful, professional and dignified workplace. We value diversity in our workforce, and are committed to equal opportunity and compliance with all fair employment practices and nondiscrimination laws.

We comply with all equal employment opportunity laws in all business dealings and all employment practices. We do not discriminate on the basis of race, color, religion, sex, national origin, age, disability, sexual orientation or status as a Vietnam-era veteran, special disabled veteran or any other status protected by applicable law. We also provide reasonable accommodation to qualified individuals with disabilities in accordance with applicable law.

Unlawful harassment or intimidation, whether sexual or racial or otherwise, is not tolerated. Retaliation for raising good faith claims of discrimination or unlawful harassment is prohibited.

Occupational Safety and Health

We care about the safety and health of our employees and visitors to our facilities. Employees must comply with all occupational safety and health laws applicable to their activities.

Community Service

We value community service and are committed to contributing to the communities in which we work and live. We actively encourage and support employee participation in volunteer community activities and proudly provide opportunities for volunteer service in partnership with community groups and service organizations.

Environmental Compliance

We respect our communities and we conduct our business in an environmentally responsible manner. We are required to comply with all applicable environmental protection laws and regulations.

Confidential Information, Intellectual Property

Our confidential information is a valuable asset that plays a critical role in our business success.  We protect our confidential information against unauthorized access and inappropriate disclosure, and we take precautions to protect it from damage or loss. Likewise, we behave ethically with respect to confidential information belonging to others. We cooperate with our customers in safeguarding confidential patient information that the Company obtains through the customers.

Books and Records of Account

All BARD records and reports must be maintained accurately to assure compliance with law and adherence to our ethical standards and to prevent fraudulent activities and errors. We follow all applicable laws and relevant accounting standards in maintaining and presenting accounting records and reports produced from those records. We do not knowingly give any false, misleading or incomplete information to anyone (external or internal) who is preparing or conducting any authorized audit of Company.

Ethical Relations with Customers

We do not give or offer anything of value to illegally induce a purchase of our products or services. Our interactions with customers must not violate any laws and must be consistent with applicable professional or industry codes (for example, in the United States, the AdvaMed Code of Ethics  on Interactions with Health Care Professionals).

Gifts and Business Courtesies

Modest business courtesies (for example, meals or travel) are, in certain circumstances, appropriate and conducive to effective business interactions.  However, such courtesies are prohibited unless modest in value and otherwise compliant with applicable law and industry or professional codes.  Entertainment and recreation are prohibited.  Further, any gift to a health care provider must benefit patients or serve a genuine educational function or benefit the provider in the furtherance of the provider's health care practice.
Courtesies such as meals and receptions, when permitted, must be modest in value and related to a legitimate business purpose (for example, product demonstration, product offerings or training), subordinate in time and focus to the business at hand and in a setting that is conducive to the pertinent exchange of information.

Donations and Grants

We may provide support for bona fide medical research, education and enhancement of professional skills, and we may underwrite continuing medical education and professional meetings in a manner that is permitted by applicable law and consistent with applicable professional or industry codes.  We may make donations to charitable organizations that are customers or affiliated with customers only where the donation involves a public benefit such as promoting the advancement of medical technology or patient care or where it serves a genuine educational purpose, or otherwise as a matter of good corporate citizenship.

Payments to Customers

The Company may hire customers to perform bona fide research, consulting, training or other services, where the services provided are of genuine value to us.  We will pay no more than fair market value for such services, and otherwise comply with all applicable law and industry or professional codes.

Training in the Safe and Effective Use of Our Products

We have a responsibility to provide our customers with appropriate instruction, education and training in the safe and effective use of our products. Payment of training fees to trainers, and reimbursement of any travel, lodging or meal expenses for participants, must comply with applicable law and any applicable industry or professional codes.

Dealings with Governments and Other Public Bodies and Their Employees

Inside Information - Securities Trading

Trading in securities while aware of material, nonpublic information is illegal. No BARD employee, officer or director may trade in the Company's stock or have someone else do it for them, when he or she is aware of material, nonpublic information.  Similarly, it is against the law to give anyone material, nonpublic information. This prohibition also applies with respect to trading in securities of another company when we are aware of nonpublic information that is material to the other company's securities.

Reporting Material Information to the Investing Public and Securities and Exchange Commission

BARD is committed to ensuring that information in its public communications, including reports and documents furnished to the Securities and Exchange Commission, be full, fair, accurate, timely and understandable. We are required to avoid selective disclosure of material, nonpublic information.

Conflict of Interest

Every employee, officer and director must act in the best interests of BARD and avoid situations that involve, or may be reasonably expected to involve, a conflict between his or her interests and the interests of BARD.  We select vendors and other business partners on the basis of such considerations as quality, price, reliability, service and delivery terms, not based personal friendships or family connections or potential of personal financial gain.  We do not accept gifts or loans or any other valuable benefit from suppliers except inexpensive, noncash gifts if permitted by applicable law and consistent with local business custom and any applicable professional or industry codes. 

BARD employees must not participate in any business dealings that would allow them to profit, directly or indirectly, because they are an agent, owner, stockholder, employee, officer or director of a BARD supplier, competitor or customer.

Antitrust Laws

We comply with antitrust, fair competition and anti-monopoly laws of the countries in which we conduct business. We support the intent of these laws to foster fair competition and protect consumers from unfair business practices.  We do not enter into collaborative action with any competitor without prior consultation with the Law Department, and we do not engage in prohibited activities.

Import and Export Laws, Economic Sanctions and Anti-boycott Laws

BARD, our agents and representatives must comply with all applicable laws governing the export and re-export of products and technology form the United States and other countries in which we conduct business. We must obtain and comply with all necessary export licenses to ensure that our products are not improperly exported or diverted to prohibited persons or to destinations that are subject to sanctions imposed by the U.S. or any other country. 

We must also comply with the laws and regulations governing the importation of products into the United States and the local import laws and regulations of the countries in which our products are sold. We accurately report the quantity and value of imported goods to the applicable customs authorities and ensure that our products are labeled and marked in accordance with United States and local customs regulations.

We will not cooperate with, further or support any prohibited boycott intended to discriminate against other persons based on race, religion, sex, national origin or nationality.

Employee Responsibility

Compliance with the BARD Business Ethics Policy is the responsibility of all officers, employees and, as applicable, our directors. Compliance is monitored by supervisors, under the guidance of corporate officers and the Compliance Coordinator, and is subject to audit.

At least once each year, each BARD employees must sign a statement that he or she has received a copy of the Business Ethics Policy and that he or she understands the Policy and that compliance with it is mandatory. At least once each year, corporate officers and other key employees must confirm in writing that they have conducted all operations under their supervision in accordance with the Policy. New employees  receive a copy of the Business Ethics Policy during orientation, are required to read it and must sign a statement that they understand the Policy and have received a copy.

What to Do if You Suspect a Violation or Have any Concerns or Questions
Employees are encouraged and expected to report to their supervisor, local management or to the Compliance Coordinator, or by calling the toll-free Compliance Line discussed below, if they suspect any violation of the law or of the Business Ethics Policy. There is no penalty for good faith reporting of any suspected violation, and BARD policy prohibits retaliation against anyone for making a good-faith report. Reports may be made anonymously. All reports of suspected violations are taken seriously and will be promptly investigated by the Company as appropriate. The identity of the person making the report and the fact that a report was made will be kept confidential except as otherwise required by law, and to the extent possible while allowing an investigation to proceed.

The Compliance Line

The Compliance Line is a telephone number that is available 24 hours a day, 7 days a week. Calls to the Compliance Line cannot be traced. The toll-free number for calls from within the United States is 877-285-4158. Calls from other locations require that you first dial a country-specific AT&T Direct access code. The list of AT&T Direct access codes may be found at AT&T's website: www.att.com/traveler.

Contacting the Non-Management Directors or Audit Committee of the Board

You may also use the Compliance Line to contact the non-management members of the Board of Directors, or bring complaints or questions about accounting, internal controls or auditing matters to the attention of the Audit Committee of the Board, or you may e-mail them at Directors@crbard.com or write to them at the address of the Company's corporate offices: C. R. Bard, Inc., 730 Central Avenue, Murray Hill, NJ 07974.

Penalty for Violation of Policy

In addition to any penalties imposed by law, any employee who has violated the law or the Business Ethics Policy will receive prompt and appropriate discipline, which may include termination of employment.