Code of Business Conduct

Code of
Business Conduct
Dear Colleague:
I’m pleased to present our Code of
Business Conduct. This is a critically
important document because it
describes our company’s expectations
of every employee as we represent
Abbott in our daily work.
Abbott has a long history of doing business the right way. More
than 125 years ago, our founder, Dr. Wallace Abbott, was one of
the creators of what was known as the ethical pharmaceutical
industry, which first established the high standards of safety and
efficacy that are the foundation of the modern health care business.
Our Code crystallizes and builds on those principles to carry
this great tradition around the world and into the future.
PAGE 2 ABBOT T CODE OF BUSINE SS CONDU C T

It’s up to each of The fundamental message of the Code is straightforward: It’s up
to each of us, as Abbott employees, to build our company and our
us to build our brand by holding ourselves to the highest ethical standards and
company and our by living our values and continually operating with honesty,
brand by holding fairness, and integrity.

We earn our reputation every day by the decisions we make and
ourselves to the the actions we take. Our Code embodies our values and provides
highest ethical a foundation for our responsibilities and behaviors that will
standards. help us make the best choices for Abbott, for ourselves, and
for the many people we serve. Abbott’s Board and our company
leadership fully support the Code and the policies, procedures
and principles it embodies.
We all share in the responsibility to live our values every day.
That includes keeping a watchful eye on our business activities
and reporting concerns in good faith without fear of retaliation.
Our work at Abbott is of the utmost importance to the people we
serve. Our products affect people’s health and lives in the most
crucial ways. That obliges us to not just follow the letter of the
laws that govern our work, but also the spirit and the ethical
expectations that come with being a leader in a business as
important as ours.
Thank you for incorporating the principles and values expressed
in our Code into your daily work for Abbott, and for all you do
to make our company great.
Miles D. White
Chairman of the Board and Chief Executive Officer

CONTENTS
1 OUR CODE IN AC TION 5 O U R P EO P L E 7 H O W W E O P E R AT E
Honesty, Fairness Collaboration Fair Dealing
and Integrity
Our Connection Avoiding Conflicts of
Decision Making to Each Other Interest
Reporting Concerns Protection of Abbott Assets
2 O U R C U S TO M E R S & Reputation
Equal Opportunity
Patients and Consumers Confidential Information
Fair Treatment
Health Care Professional Anti-Bribery
Work Environment
Judgment
Gifts, Meals &
6 O U R CO M M U N I T I E S Entertainment
3 OUR PRODUCTS
Accurate Books & Records
Community Involvement
Product Quality
Compliance with Laws
Political Contributions
Product Promotion
Fair Competition
Environmental
Responsibility Applicability
4 A DVA N C I N G S C I E N C E
Innovation Waivers & Amendments
Advancing Science
8 RESOURCES
Decision Making AID
Speak Up
Other Important Resources

1
OUR CODE
IN AC TION
The promise of our company
is in the promise that our work
holds for health and life.
We live that promise through
the actions we take each
and every day.
I N T H I S S EC T I O N
Honesty, Fairness and Integrity
Decision Making

OUR CODE IN ACTION
H O N E S T Y, FA I R N E S S A N D I N T EG R I T Y
It is up to every person working for Abbott – at all levels of the
organization – to uphold the Abbott values (Pioneering, Achieving,
Caring and Enduring) and operate with honesty, fairness, and
integrity. Abbott’s long-term success depends upon the choices
we make every day. We are all responsible for understanding how
this Code applies to our work and decision-making, operating at all
times in line with this Code, and for promoting compliance with
this Code by others operating on Abbott’s behalf. The fundamental
message of the Code is straightforward: It’s up to each of us, as
Abbott employees, to build our company and our brand by holding
ourselves to the highest ethical standards and by operating with
honesty, fairness, and integrity.
It is up to every person working for

Abbott – at all levels of the organization –
to uphold the Abbott values and operate
with honesty, fairness, and integrity.

OUR CODE IN ACTION
D EC I S I O N M A K I N G
Abbott is a global company. We conduct business in over 150
countries around the world and our employees are citizens of
many nations with diverse cultures and beliefs. We must recognize
the global impact of our actions and decision making and realize
that Abbott is subject to many laws, regulations, and other
requirements that vary across the countries in which we operate.
Each of us will, at times, be faced with situations where the right
course of action about a new situation is hard to determine. We are
all expected to understand the Abbott principles embodied in this
Code, along with the Abbott policies and procedures applicable to
our work. Many additional resources are available at Abbott for
advice and guidance, including:
Colleagues Learn more about the different

channels available to ask
Managers and supervisors questions and raise concerns in
the Speak Up section.
The Office of Ethics and Compliance
Human Resources
The Legal Division

OUR CODE IN ACTION
D EC I S I O N M A K I N G CO N T I N U ED
These resources can help guide decision making. Our decision
making AID is also available to help work through issues when the If you are unsure about the
best path forward is not obvious. This tool provides an approach to right course of action, follow the
thinking through the alternatives to, and impacts of, decisions we steps outlined in the Decision
may face in our work. Making AID section.
In addition, help is always available to ensure understanding of this
Code’s requirements. General assistance and contact information
for your local or regional Office of Ethics and Compliance
personnel is available on the OEC website (abbottworld.abbott.
com/EthicsCompliance).
We must recognize the global impact

of our actions and decision making.

2
OUR
CUSTOMERS
We improve health for
patients, consumers,
and communities.
Patients and Consumers
Health Care Professional Judgment

OUR CUSTOMERS
PAT I EN T S A N D CO N S U M ER S
We prioritize the health and well-being

of patients and consumers.
We are passionate about helping people lead healthier lives. Each
and every day, we have the opportunity to improve people’s lives Learn more about our
and create healthier societies through our work. Caring for people commitment to patients and
is fundamental to what we do, and it is both a tremendous privilege consumers: abbott.com/about-
and a great responsibility. abbott/who-we-are.html
H E A LT H C A R E P R O F E S S I O N A L J U D G M EN T
We respect the expertise of health care

professionals who provide guidance
about health care treatment options and
healthy living.
Health care professionals, such as physicians, pharmacists,
nurses, researchers or laboratory staff, must use their independent
judgment to decide the best course of care for their patients based
on their training and expertise. We are committed to working with
health care professionals to provide them with timely and accurate
information to assist them in making decisions and providing
advice to their patients. We can achieve our mission of supporting
health only through a truly collaborative approach.

3
OUR
PRODUC TS
We earn Abbott’s positive
reputation by consistently
delivering high quality
products.
Product Quality
Product Promotion

OUR PRODUCTS
P R O D U C T Q UA L I T Y
We produce and deliver safe, Learn more about our products:

www.abbott.com/our-products.
effective products that people trust. html
We endeavor to maintain the highest level of quality throughout
our business. This effort starts with the sourcing of materials
and the manufacture of our products and moves through how
we market, sell, and supply our products, including through our
business partners – delivering high quality is imperative every
step of the way. Our commitment to the health and safety
of the people who use our products is always at the forefront
of everything we do.
WHAT DO I DO IF
SOMEONE TELLS ME ABOUT
A PRODUCT QUALITY ISSUE?
Q: What do I do if someone tells me about a product
quality issue?
A: If we become aware of an unfavorable user result that
occurred while using an Abbott product, we must report it to
the appropriate individuals or groups within Abbott.
We must report adverse events with any of our products in
the timeframe required by our division procedures, even
if we are not sure there is a cause-and-effect relationship
between the product and the “event.”

OUR PRODUCTS
P R O D U C T Q UA L I T Y CO N T I N U ED
We are committed to timely identifying, evaluating, and addressing Learn more about our quality
product safety issues. We provide health care professionals procedures: abbottworld.abbott.
and institutions with the information they need in order to use com/Quality
Abbott’s products safely and effectively, and we communicate
with regulatory or public health agencies in the event of potential
safety concerns.
We take action to prevent counterfeiting, illegal diversion,
and theft of our products. We adhere to all applicable trade
regulations, such as export and import controls issued by the
United States and other governments for foreign policy and
national security reasons. Trade regulations include sanctions,
restrictions on exporting of certain products, and prohibitions on
conducting business with certain individuals, groups or entities.
P R O D U C T P R O M OT I O N
We promote and sell our products Learn more about the U.S.
Food, Drug, and Cosmetic Act:
with honesty and integrity. fda.gov/regulatoryinformation/
Our statements about our products, in all materials and legislation/federalfooddrugand
communications, will be balanced and truthful and consistent cosmeticactfdcact/default.htm
with the approved label. In promoting our products, we provide
information that is consistent with scientific evidence, leading
medical practice, and the approved product labeling requirements
in the countries where we operate.

OUR PRODUCTS
P R O D U C T P R O M OT I O N CO N T I N U ED
We promote our products for the

purposes for which they are intended
and approved.
Abbott’s activities conform to the regulatory licenses and
approvals we obtain from government agencies such as Ministries
of Health, or Food and Drug authorities, to promote, sell, and
import pharmaceuticals, medical devices, and other products.
We comply with each country’s laws and regulations that govern
how, where and when we are permitted to promote our products,
such as the United States Federal Food, Drug, and Cosmetic Act.
We maintain and follow internal policies and procedures designed
to ensure compliance with such requirements and with respect
to government health care programs.
WHAT IS ABBOTT’S POLICY

ON PRODUCT PROMOTION?
Q: What do Abbott policies and body for the location or usage in
procedures require with respect to question. If a health care professional
product promotion? asks about uses for Abbott products
that are beyond the scope of approved
A: One of the key, universal principles
labeling (sometimes referred to as
related to product promotion is that
“off-label” uses), the inquiry should be
we may not promote or pre-sell a
directed to the designated function for
product that has not yet been approved
such inquiries in your division, which
or cleared by the relevant regulatory
normally resides in Medical Affairs.

4
ADVANCING
SCIENCE
We advance science,
technology, and product
innovation to work toward
a healthier future.
Innovation
Advancing Science

A D VA N C I N G S C I E N C E
I N N OVAT I O N
We innovate and advance health care

solutions and product innovations
to improve health outcomes around
the world.
We address human needs by pioneering innovative treatments
and products, lifesaving medical devices, and new approaches to If you are unsure about the
managing health. We advance leading-edge science, technology, right course of action, follow the
and product innovations to foster improvements to health. Good steps outlined in the Decision
health is key to our customers maximizing their full potential. Making AID section.
We support patients’ and consumers’ pursuit of health throughout
the continuum of life, providing innovative products designed
to help people live the healthiest, fullest lives possible. We focus
on innovation of products that change lives for the better.
We foster a culture of innovation,

seek new possibilities, and plan for
contingencies.
Our relentless drive toward innovation and new possibilities
comes with risk. While we take measured risks that are consistent
with this Code and our policies, we should always make efforts
to mitigate risks in advance, considering possible outcomes,
and plan accordingly.

A D VA N C I N G S C I E N C E
A DVA N C I N G S C I EN C E
We conduct research to obtain and

provide objective, accurate data that
will advance science.
We conduct research to advance the science behind our
products: to develop new products, improve existing We are committed
treatments, and advance health care practices. to treating study
When we conduct research, we are committed to treating study participants with
participants with dignity and respect, and to protecting them
from unnecessary risk. We ensure that patients participating
dignity and respect,
in research understand the nature and purpose of the research and to protecting
and the associated risks. Obtaining informed consent from study them from
participants is an essential part of our research process.
unnecessary risk.
We value transparency in scientific research, and will not attempt
to improperly influence the outcome of any research or reports
made by clinical investigators or other researchers. We recognize
the importance of ensuring that data from studies and related
analyses are accurate. We are committed to providing research
results relating to our products, whether results are positive or
negative, in a timely and accurate fashion.
When research is done for Abbott or published on our behalf, we
select partners with strong medical and scientific backgrounds.
We have high standards for these partners, such as expecting
investigators to appropriately disclose their connection to
Abbott. When we partner with other scientists or clinicians
in connection with research and development work, we are
committed to complete and accurate disclosure of financial
or other relationships.

5
OUR
PEOPLE
We value our diverse
perspectives as a
source of strength.
Collaboration
Our Connection to Each Other
Reporting Concerns
Equal Opportunity
Fair Treatment
Work Environment

OUR PEOPLE
CO L L A B O R AT I O N
We foster a culture of openness,

recognizing that diversity of thought
and collaboration drive innovation.
We embrace diversity because we believe that it generates
creativity, innovation, and energy. We understand that to make
a difference and address a wide spectrum of changing health
needs, it takes a relentless drive and a collaborative approach,
listening to our colleagues and ensuring that all voices are heard.
O U R CO N N EC T I O N TO E AC H OT H ER
We all share in the responsibility to live our values every day.
By demonstrating and supporting ethical behavior, we positively
impact the culture of Abbott. We are all responsible for
understanding how this Code applies to our work and the
role we perform in the company.
Managers and supervisors, as leaders in the organization, must We all share in
demonstrate a strong commitment to our values and lead by
example. They must always promote and support ethical behavior
the responsibility
by employees. Managers must help ensure that employees to live our values
understand their responsibility to abide by this Code and every day.
must foster a work environment that allows employees to
feel comfortable asking questions and voicing concerns
without fear of retaliation.

OUR PEOPLE
R EP O R T I N G CO N C ER N S
We ask questions whenever choices or

actions related to our work are unclear
or do not seem right, and we speak up WHY
and report any violations of this Code. SHOULD I
It is up to each of us to ask questions whenever we feel direction REPORT A
is unclear, and to challenge and report any suspected unethical CONCERN?
business conduct, violation of this Code, or violation of our policies
Q: Why should I report
or procedures.
a concern?
Asking questions, reporting concerns, and actively pursuing clarity
A: We all share in the
about our choices or actions helps us identify and avoid problems
responsibility to live our
more effectively. When in doubt about the right choices, actions
values every day. That
or potential violations, ask a manager or the Office of Ethics
includes keeping an open
and Compliance.
dialogue by asking questions
Managers and supervisors have a fundamental responsibility when we don’t know what
to lead by example and ensure that employees understand and to do and reporting concerns
are held accountable to the Code. Those in leadership roles carry related to our business
heightened responsibility for understanding and communicating activities.
Abbott’s expectations, and should contact the Office of Ethics
Raising a concern on
and Compliance regarding potential Code violations.
noncompliance continues
All reports of potential Code violations will be taken seriously our commitment to act
and handled appropriately through follow up steps such as ethically in all aspects of
investigation, remediation, and where necessary, corrective our business and fosters
actions to address issues, learn from mistakes, and avoid a culture of compliance.
recurrence. The Office of Ethics and Compliance will direct any Your actions can make a
investigation of alleged violations of the Code. You should not difference.
conduct any investigation independently. Each of us is required
to cooperate in, and maintain the confidentiality of, any
such investigation.

OUR PEOPLE
R EP O R T I N G CO N C ER N S CO N T I N U ED
Corrective actions related to Code violations may include Learn more about the policies
disciplinary action (up to and including termination), and procedures related to
or legal action for: the Office of Ethics and
Compliance: icomply.abbott.
com
Authorization of or participation in a violation;
Refusal to cooperate in the investigation

of an alleged violation;
Failure by a violator’s supervisor(s) to detect

and report a violation, if such failure reflects
inadequate supervision or lack of oversight;
Reporting a concern that is knowingly false,

or is intended to threaten, intimidate or
retaliate against any person associated
with Abbott’s business;
Retaliation, such as by intimidating, threatening,

harassing or maligning any person who has
reported a violation or potential violation
in good faith.

OUR PEOPLE
R EP O R T I N G CO N C ER N S CO N T I N U ED
It is never acceptable to retaliate against anyone who raises Learn more about the different
concerns about whether business activities are in line with channels available to ask
the Code. Alleged retaliation should be reported to the questions and raise concerns in
Office of Ethics and Compliance or Human Resources. the Speak Up section.
Our commitment to the work that we do drives us to not
just follow the letter of the laws that apply to our work,
but to be mindful of the ethical expectations that come
with being a leader in a business like ours.
WHAT IF
I FACE RETALIATION?
Q: What if I face retaliation?
A: The company strictly forbids any
retaliation against any person who raises
a concern. Complaints made in good faith
will not expose you to any sanctions,
regardless of whether the underlying facts
prove to be correct. If you believe you have
faced retaliation of any kind, please report
it so that the company can investigate.

OUR PEOPLE
EQ UA L O P P O R T U N I T Y
We provide equal opportunities

for all employees.
We base employment decisions on business needs, skills,
experience, and relative work performance. Abbott prohibits Learn more about our diversity
discrimination based on race, color, religion, creed, age, sex, and inclusion programs: abbott.
national origin, gender identity or expression, sexual orientation, com/careers/diversity-and-
disability, marital status, veteran or military status, genetics or inclusion.html
citizenship status, or any other legally protected status. We are
committed to following the laws impacting our relationship
with our employees around the world.
FA I R T R E ATM EN T
We strive to ensure that everyone

working at Abbott feels welcome,
supported, and inspired to succeed.
Abbott cares about and is concerned for the health and well-being
of its employees worldwide. Everyone who works at Abbott should
encounter a professional environment, free from intimidation
and harassment. Abbott encourages input from its employees
on ways to enhance the inclusive and diverse atmosphere of its
workplaces and promotes a workplace that is free from disruptive
conduct by employees.

OUR PEOPLE
FA I R T R E ATM EN T CO N T I N U ED
We treat everyone with Learn more about our

workplace harassment policy:
respect and dignity. myhr.oneabbott.com/
Our respect for people is demonstrated in what we do and how GL-EN/English%20
we act toward everyone we encounter in our work. To meet Documents/C-111%20
our commitments to one another, and to attract, cultivate and Workplace%20
retain talented individuals from around the world, it is vital to Harassment_0_.pdf
have a work environment built on mutual trust, respect, and
the principles embodied in this Code. We must treat others
equitably and not take advantage of others through manipulation,
misrepresentation, or concealment.
W O R K EN V I R O N M EN T
We take care to ensure workplace Learn more about our

safety and appropriate conditions environmental health
and safety program:
for employees and others who abbottworld.abbott.com/
work for us. EnvironmentalHealthSafety
Accidents and unsafe situations must be promptly reported

to management. We also take steps to prevent and prohibit
illegal and inappropriate labor conditions, and cruel or inhumane
treatment, in connection with our business activities around
the world.

6
OUR
COMMUNITIES
We build trust in Abbott
as a citizen of each local
community and the world.
Community Involvement
Political Contributions
Environmental Responsibility

OUR COMMUNITIES
CO M M U N I T Y I N VO LV E M EN T
We strive to foster community well-being

through our products and our work.
We have a distinguished history of supporting the communities
where we live and work. We believe that with good health, Learn more about our global
communities can thrive. Through our operations, business citizenship program: abbott.
relations, and support of community groups and charitable com/abbott-citizenship.html
causes, we give back to our communities and our neighbors. In
communities large and small, wherever we do business, Abbott
strives to make a positive and lasting difference in people’s lives.
P O L I T I C A L CO N T R I B U T I O N S
We encourage appropriate engagement

in the political process and support
community involvement.
Abbott works to support public policy that aligns with our
mission and values and, where appropriate, may provide support
to political candidates or interest groups. The laws related to
political contributions by companies are complex, so it is important
that contributions of Abbott funds and any other contributions
provided on behalf of Abbott be made only after consultation
with the Legal Division.

OUR COMMUNITIES
EN V I R O N M EN TA L R E S P O N S I B I L I T Y
We engage in sustainable development

and endeavor to minimize our impact
on the environment.
We are committed to minimizing our global environmental impact,
from the responsible sourcing of raw materials to the manufacture, Learn more about our
distribution and use of our products. environmental program:
abbottworld.abbott.com/
We take steps to reduce our use of energy and other natural
EnvironmentalHealthSafety
resources. We support projects that generate energy from
renewable sources at work and in our communities. We seek
ways to reduce the environmental impact of our operations,
such as through waste reduction and recycling and other activities
to mitigate environmental risks. We adhere to the environmental
laws and regulations applicable to our operations.

7
HOW WE
OPERATE
We work together with
accountability and in keeping
with Abbott values.
Fair Dealing Gifts, Meals and Entertainment
Avoiding Conflicts of Interest Accurate Books and Records
Protection of Abbott Assets & Compliance with Laws
Reputation
Fair Competition
Confidential Information
Applicability
Anti-Bribery
Waivers and Amendments

H O W W E O P E R AT E
FA I R D E A L I N G
We conduct business ethically and

honestly, and strive to do what we say
we will do, in all aspects of our work.
We are each accountable for our work and decision-making
within the realm of our roles and responsibilities. If you are unsure about the
right course of action, follow the
In all of our professional interactions, with all of the people we
steps outlined in the Decision
encounter in our work – coworkers, customers, suppliers, health
Making AID section.
care professionals, competitors, and others – we must be fair
and straightforward about how Abbott conducts business.
This principle of fair dealing is critical.
AVO I D I N G CO N F L I C T S O F I N T ER E S T
We address and resolve any conflicts

of interest before moving forward.
A conflict of interest exists whenever an Abbott employee’s private
interests interfere, or appear to interfere, with Abbott’s interests.
Business decisions should be based on Abbott’s needs, rather than
potential personal gain or the interests of family or friends. Each
of us is expected to use good judgment and to avoid situations that
can lead to an actual conflict or the appearance of a conflict.

AVO I D I N G CO N F L I C T S O F I N T ER E S T CO N T I N U ED
If competing actions, interests, or relationships make it difficult Learn more about how to
to perform your work objectively and effectively, or if you or a avoid, or disclose and manage,
family member could receive improper personal benefit as a result potential conflicts of interest:
of a position with or connection to Abbott, you must disclose the speakup.abbott.com
potential conflict of interest in accordance with Abbott’s conflict
of interest guidelines and excuse yourself from situations where
the conflict could impact your business judgment.
IS IT OKAY TO TAKE ON
EMPLOYMENT OUTSIDE OF ABBOTT?
Q: I work in Finance and, because the disclosure of confidential
of my academic performance, information from Abbott.
I have always been in contact Is this a conflict of interest?
with the academic world, so a
A: Because outside employment
University has contacted me
could pose a conflict of interest, you
to teach classes on Analysis
were correct to disclose the potential
and Evaluation of Financial
conflict of interest and discuss with
Statements. I’ve discussed with
your manager. After you’ve consulted
my manager, and we agree that it
with your manager, evaluated the
is a job where the functions are
situation together, and determined
completely independent of those
that the new job does not affect the
in Abbott; the work schedule does
performance of duties for Abbott, this
not interfere with my Abbott
situation would not be considered a
work and it does not require
conflict of interest.

AVO I D I N G CO N F L I C T S O F I N T ER E S T CO N T I N U ED
We place the interests of Abbott above

personal interests when making
decisions in connection with our work.
The interests of the greater organization should be prioritized
over the interests of a business division, a working group,
or an individual in the context of our work.
Our positions at Abbott and opportunities, such as outside business
deals or financial interests, made available through work activities,
should only be used for Abbott’s benefit, and not for personal gain.
We should not compete with Abbott or help other individuals or
businesses do so. Our priority must be to advance the company’s
interests when opportunities arise.

P R OT EC T I O N O F A B B OT T A S S E T S & R EP U TAT I O N
We are caretakers of our company

in our work. Learn more about our social
It is our responsibility to protect and use Abbott’s assets, from media policy: collab.oneabbott.
physical property, like vehicles and computer equipment, to com/CORP/IRPA/SMRC
intellectual property, trade secrets, and know-how, with care
and ensure their efficient and proper use. We must all use good
judgment to ensure that Abbott’s assets are not lost, stolen,
misused, or wasted.
Abbott’s reputation is one of its greatest assets. We are each
responsible for enhancing and protecting Abbott’s reputation.
We are each personally accountable for any views or content
published or shared with people outside the company.
CAN I USE MY WORK

COMPUTER FOR
PERSONAL USE?
Q: Can I use my work computer to do online shopping
during the holiday season?
A: Abbott Policy allows employees to use Abbott’s computers
for this type of personal use as long as it is incidental and
does not conflict with work responsibilities. For more
information, see Abbott’s Electronic Use Policy.

P R OT EC T I O N O F A B B OT T A S S E T S & R EP U TAT I O N
CO N T I N U ED
Learn more about our
In external interactions, we need to be mindful of whether we policy on electronic media
can be identified as affiliated with Abbott, and consider how any use: myhr.oneabbott.
statements related to our work may reflect on the company. com/GL-EN/English%20
This is especially crucial in the context of social media where Documents/C-118%20
interactions are quick and dynamic and can become highly Electronic%20Media%20Use.
visible. Careless communications can pose a significant risk to pdf
Abbott’s reputation. We are all responsible for employing careful
communication strategies in our communications and protecting
Abbott’s confidential information.
CO N F I D EN T I A L I N F O R M AT I O N
We respect and safeguard confidential

information, including personal
information.
One of Abbott’s most valuable assets is its confidential
information. Confidential information is information that is
not publicly available and includes research and development
projects, trade secrets, business plans, manufacturing formulas
and processes, supplier or customer contract terms, pricing, sales
figures, bids, quotes, pricing proposals, responses to tenders, and
non-public financial results, or any other information that might
be of use to Abbott’s competitors or harmful to Abbott if disclosed.
Each of us must be vigilant to safeguard confidential information
and prevent unauthorized disclosure or use. Confidential
information should not be shared with competitors. These
obligations may extend beyond employment with Abbott.

CO N F I D EN T I A L I N F O R M AT I O N CO N T I N U ED
Similarly, we respect the intellectual property rights of Learn more about our policy on
others and will not inappropriately obtain or misuse their Insider Trading: abbottmfiles.
confidential information. oneabbott.com/Default.
Misuse of specific confidential information is prohibited by aspx?#3E4088E6-D40A-
law, such as laws prohibiting insider trading based on non-public 4DA2-90B9-76B55D51A390/
information. Insider trading is both unethical and illegal, object/0/9698/latest
and we must not buy or sell securities of Abbott, or of other
companies doing or expected to do business with Abbott,
based on such information.
WHAT DO I
DO IF I SEND
SOMETHING TO THE
WRONG PERSON?
Q: What do I do if I have inadvertently
sent a list of patient names and email
addresses to the wrong external email
recipient?
A: Patient names and other patient
information are considered sensitive
information we need to protect. If such
information has been compromised in any
way, you should follow internal processes to
notify relevant internal stakeholders about
the incident. You should contact Abbott’s
Global Service Desk to report this incident.

CO N F I D EN T I A L I N F O R M AT I O N CO N T I N U ED
We respect the privacy of those who entrust their personal Learn more about the
information to us, including our colleagues and the people privacy and data protection
who recommend, prescribe, and use our products. When we requirements for your location:
collect personal information in the course of our business, we abbottworld.abbott.com/Legal/
appropriately inform the people whose information we collect GBLPRIV
about how it will be used, and obtain appropriate consent or
authorization. We do not sell personal information or obtain
personal information from sources that do not have authorization.
We protect personal and sensitive information from unauthorized
disclosure and use. Many locations have strict regulations
requiring companies to protect personal information collected
and used in the course of business, especially for the most sensitive
categories of personal information, and we are committed
to understanding and following these requirements.
HOW DO I RESPOND A: Providing information that is non-

public about Abbott’s business could be a
TO AN INQUIRY problem. Some people contacting Abbott for
FROM THE GENERAL information of this nature are trying to piece
together information from different sources
PUBLIC OR PRESS? to gain an insider view of what is happening
Q: What should I do if I receive a call at our company. Until Abbott is ready to
or an inquiry online from someone publish its results or other information about
asking me about the latest news from our business, you should keep information
Abbott? The person who called me about your work confidential. Be sure to know
seemed very professional, and indicated what is considered confidential and non-
that he is doing a formal survey across confidential with respect to the information
the health care industry about current related to your work. If you have questions,
industry developments. Am I allowed to contact your manager, OEC or Legal. Refer
participate? press inquiries to Public Affairs.

A N T I-B R I B ER Y
We actively oppose fraud, bribery,

and corruption. We get business
the right way.
As patients, family members and care givers, we want our
doctors, nurses and pharmacists to recommend the products and
treatments that will best suit our needs, using their professional
judgment. Patients and consumers should be able to rely on the
independent judgments of their health advisors, without concern
that those judgments have been improperly influenced
by incentives from companies seeking to promote their products.
As citizens, we want our government officials to make decisions
that serve the best interests of the people. Such government
decisions should not be improperly influenced by companies
seeking favor for their corporate interests through incentives
to government officials.
As we market and sell our products, we educate and inform health
care professionals, but do not interfere with their independent,
professional judgments. It is never permissible to offer or provide
anything that directly or indirectly benefits a government official,
a health care professional (such as a physician, pharmacist, nurse,
researcher or laboratory staff), or any other person, in order to
make a sale or secure a business advantage for Abbott. Similarly,
it is never acceptable to provide anything of value as a “reward”
for any past or existing relationship with Abbott.

A N T I-B R I B ER Y CO N T I N U ED
Anti-bribery, anti-corruption, and “anti-kickback” laws make it
especially important that we demonstrate our commitment to Learn more about anti-bribery
preventing improper influence in business transactions in all of and anti-corruption laws from
our interactions. The U.S. Foreign Corrupt Practices Act, the U.K. around the world:
Bribery Act, and other relevant laws potentially apply to Abbott’s http://abbottworld.abbott.
activities around the world, and bribery is illegal everywhere. com/Legal/anticorr
Everyone at Abbott must proactively manage relationships with

service providers (such as distributors, consultants, speakers or
promoters) to ensure that services performed on Abbott’s behalf
are carried out in accordance with our expectations and in
compliance with applicable laws and regulations. We must use due
diligence when selecting service providers, pay fair market value
for services, and accurately document payments for services,
fines, fees and the like.
WHAT IS THE DIFFERENCE BETWEEN A

BRIBE AND A LEGITIMATE PAYMENT TO GET
A SERVICE PERFORMED MORE QUICKLY?
Q: How do I tell the difference between published, with a set fee, and accompanied
a bribe and a legitimate payment to get a by clear, standard documentation such as
service performed more quickly, like when an application form and receipt from the fee
I want to apply for a visa or seek customs issuing entity. Abbott policies and procedures
clearance on a “fast-track” basis? do not allow “facilitation payments,” which
are different from such legitimate “fast-track”
A: Some differences include the amount of
options. If you are unsure whether a payment
documentation and whether the same option
to get services performed more quickly is
is always available to every applicant. Fees for
permitted, you should contact your manager,
legitimate “fast-track” options are normally
OEC or Legal.

G I F T S , M E A L S A N D EN T ER TA I N M EN T
Because anti-bribery principles require that we never offer
or provide anything that directly or indirectly benefits any
person to secure a business advantage, we set limits surrounding
gifts, meals and entertainment. Our policies and procedures
related to limits on and reporting of brand reminders, gifts,
cultural courtesies, meals and hospitality are in place to help
ensure that we do not provide any benefit that could interfere
with professional judgment.
CAN I OFFER A CULTURAL

COURTESY TO A HEALTH
CARE PROFESSIONAL?
Q: During national or religious holidays, are we able to
give a health care professional a cultural courtesy?
A: Cultural courtesies related to national or religious
holidays may be given in many locations, provided that they
are allowed by local procedures and do not exceed monetary
limits. You should check your local OEC procedures to
determine what items, if any, may be provided.
We never offer or provide anything that

directly or indirectly benefits any person
to secure a business advantage.

G I F T S , M E A L S A N D EN T ER TA I N M EN T CO N T I N U ED
CAN I ACCEPT A GIFT FROM A SUPPLIER?

Q: I received a gift from a supplier during the gift is modest and considered reasonable
the holidays, and I am not sure if I can based on the culture of the country, you can
accept it. What should I do? accept it, and the best approach is to share
it with the employees of the department,
A: It depends on the nature of the gift, its
if the nature of the gift permits. In both
value, and the culture of the country. If the
cases, transparency is the key element in
value of the gift you are receiving is not
such circumstances. Therefore, you should
modest, you should not accept it and return it
notify your manager about it and, if you have
to the supplier explaining that our policy does
further questions, you should contact Abbott
not permit employees to receive expensive
Purchasing.
gifts. On the other hand, if the amount of
CAN I TAKE A HEALTH CARE

PROFESSIONAL OUT FOR A BUSINESS MEAL?
Q: While on a business visit to a health A: In most countries, having a meal with a
care professional, the sales representative health care professional in conjunction with
is asked by the health care professional if a business conversation is permissible. You
they can discuss the business topics over should check your local OEC procedures for
lunch. Is this permissible according to our requirements and monetary limits.
Code of Conduct?

ACC U R AT E B O O K S A N D R ECO R D S
We measure achievements accurately.

Our financial books, internal records and documentation, and
public statements must accurately reflect the substance and facts of
our actions. When we are measuring or describing our successes,
failures, and routine operations, the facts must be presented in
sufficient context and with adequate support to understand the
true nature of our activities or transactions. Our financial records
must conform to applicable accounting standards, laws and
regulations, as well as Abbott’s policies, procedures and controls.
When we report information, such as pricing or payments and
items of value provided to physicians and other customers, the
information must be complete and accurate. Many governments
around the world have strict laws regarding price reporting and
reporting of certain payments to health care professionals.
These laws help protect taxpayers, who ultimately pay for some
or all of the purchases within the health care system. Abbott
is committed to ensuring that we provide accurate information
to allow governments, insurers and other stakeholders to
make informed decisions.
WHAT SHOULD I DO Q: What do I do if I become aware that

someone has created an “unofficial”
IF I BECOME AWARE separate account that has not been
OF A FINANCIAL reported to Finance?
IRREGULARITY? A: You should report this to OEC, Legal or

Finance so that it can be reviewed.

CO M P L I A N C E W I T H L AW S
We adhere to all laws, regulations Learn more about our corporate

and Abbott requirements that apply policies: abbottworld.abbott.
to our work. com/GlobalPolicy
Every Abbott employee is expected to adhere to all laws and

Abbott’s policies, procedures, principles and standards, including
this Code. This is a fundamental expectation and condition of
employment. Abbott’s policies and procedures cover topics related
to important aspects of our operations, including health care
compliance, quality, engineering, customs and trade, finance,
security, purchasing, human resources, and information systems,
to help ensure that we comply with the many laws and regulations
governing our business. Such policies and procedures enable us to
detect, correct and prevent non-compliant activities.
As employees of a global company, we must keep in mind that WHAT
the laws of one country may apply to the way we work in other LAWS AM I
countries. We must be mindful of the requirements for each
location, and seek guidance from the Legal Division or the Office of SUPPOSED
Ethics and Compliance whenever we face a question about which TO FOLLOW?
requirements apply.
Q: There are so many laws
around the world and in
my country, how can I
possibly know which ones
I need to follow and what
they say?
A: Abbott’s policies and
procedures are regularly
updated to accurately reflect
the changes to law. Be sure
to follow all relevant policies
and ask OEC or Legal if you
have questions.

FA I R CO M P E T I T I O N
We ensure that any interactions that we

have with competitors are appropriate.
We must compete aggressively in the marketplace to best serve
our customers’ needs and enhance shareholder value. In doing so,
we will not engage in agreements or activities that unfairly limit
competition. We are committed to complying with competition
laws in every country where we do business. These laws prohibit
agreements that eliminate or discourage competition and apply
to many aspects of our business, including relationships with
competitors, prices and terms of sale to distributors and other
customers and marketing and trade practices. Competition laws
are very complicated and penalties for violation may include high
fines and even imprisonment. It is important that you do not
engage in any activity that could be viewed as anticompetitive
and consult with Legal or the Office of Ethics and Compliance
if you have questions.
We must always exercise caution when interacting with
competitors. You should not discuss sensitive business topics
such as prices, sales terms, business or marketing plans, margins,
costs, production capacity, inventory levels or discounts with
competitors. You should contact Legal or the Office of Ethics and
Compliance for specific guidance about the laws relating to your
interactions with competitors and to report any inappropriate
conversations with competitors.

APPLICABILIT Y
This Code applies to all officers and employees of Abbott, in all
locations where Abbott’s divisions and affiliates operate around the
world. This document sets forth the actions expected from all of
us, including outside entities acting on Abbott’s behalf, whenever
conducting business for Abbott; it is not a contract of employment.
WA I V ER S A N D A M EN D M EN T S
Abbott will make public disclosure, to the extent required by
applicable laws, rules and regulations, of any waivers of, or
amendments to, this Code.
Any waiver of this Code for a person covered by this Code may be
made only by the Chief Executive Officer (or designee), except that
a waiver for an Executive Officer requires approval by the Audit
Committee of the Abbott Board of Directors.
This Code applies to all officers and

employees of Abbott around the world.

8
RESOURCES
Decision Making AID
Speak Up
Other Important Resources

RESOURCES
DECISION M AKING AID

You will at times be faced with situations where the
right course of action is hard to determine. Our decision
making AID will help you ask the right questions to
define a course of action that supports Abbott’s values.
A
Assess the course Is it legal?
of action Does it comply with Abbott policy?
Does it align with Abbott values and culture?
I
Evaluate the How will this affect the patients and consumers
possible impact of Abbott?
Could this affect Abbott’s reputation? (Would
you be concerned if this appeared in the news or
headlines?)
Could this have an impact on any of Abbott’s
other stakeholders?
D
Decide If you feel confident your decision balances the
interests of all stakeholders, proceed.
If you are still unsure about the right course
of action, consider alternatives, speak to your
manager, the Office of Ethics and Compliance,
Human Resources, and/or the Legal Division.
Check out our interactive Decision Making AID:

abbottworld.abbott.com/EthicsCompliance/cobc/Pages/Decision-Making-Aid.aspx

RESOURCES
SPE AK UP
We offer several channels where you can ask questions
and raise concerns. To learn more about our reporting
program, visit speakup.abbott.com.
ASKING QUESTIONS
If you have a question about your specific obligations, talk to your manager,
OEC, HR, or Legal.
R A I S I N G CO N C ER N S
Visit our multilingual Ethics and Compliance Helpline (http://speakup.abbott.
com) available globally 24/7 to voice your concerns about a potential violation
of our company’s values and standards of conduct.
You can also email [email protected] to report a potential violation.

RESOURCES
OTHER IMPORTANT
RESOURCES
M A N AG ER O R S U P ER V I S O R
If you have questions on how our Code of Business Conduct
applies to your specific job role, the best place to start is with your
immediate manager or supervisor.
A B B OT T CO R P O R AT E P O L I C Y P O R TA L
For our corporate policies and procedures applicable
companywide, visit the Abbott Corporate Policy Portal:
abbottworld.abbott.com/GlobalPolicy
O F F I C E O F E T H I C S A N D CO M P L I A N C E (O EC )
The OEC is a corporate resource available to address your questions
or concerns about our company’s values and standards of conduct.
OEC Website – Refer to the OEC website (abbottworld.abbott.

com/EthicsCompliance) for answers to a variety of ethics and
compliance questions. Our company’s global and country-specific
OEC policies and procedures can also be accessed from the website.
OEC Contacts – You are encouraged to contact the OEC at any

time with any ethics and compliance questions, or to discuss
concerns about possible violations of our written standards, laws,
or regulations.
orporate OEC – Call 1-224-667-5210 or email

C
[email protected] with any questions related to ethics
and compliance at Abbott.
Divisional or Country OEC – Your divisional or

country OEC representative (icomply.abbott.com/Apps/
ComplianceContacts) can provide additional guidance on
divisional or country-specific OEC policies, procedures, and
guidelines.

RESOURCES
OTHER IMPORTANT
RESOURCES CONTINUED
Ethics and Compliance Helpline – Visit our multilingual Ethics

and Compliance Helpline (speakup.abbott.com) available globally
24/7 to voice your concerns about a potential violation of our
company’s values and standards of conduct. You can also email
[email protected] to report a potential violation.
Abbott does not tolerate retaliation against anyone who

makes a good-faith report regarding a potential violation
of our written standards. In any good-faith report,
anonymity is allowed, non-retaliation is ensured, and
confidentiality is preserved.
iComply – Visit iComply (icomply.abbott.com) to access

compliance-related applications and resources geared towards
interactions with Health Care Professionals and Health Care
Organizations, as well as third parties.
HUM AN RESOURCES
For employee-related issues, such as concerns involving
management and/or other employees, contact your local
Human Resources (myhr.oneabbott.com) representative.
L EG A L D I V I S I O N
If you have questions about the laws, regulations, and
acceptable business practices, the Legal Division
(abbottworld.abbott.com/Legal) can assist you.

RESOURCES
OTHER IMPORTANT
RESOURCES CONTINUED
OT H ER R E S O U R C E S
There are many other resources available to you:
Finance – If your question is about accounting or finance, contact

your local Finance department.
Corporate Audit – If you have specific concerns regarding

accounting, internal accounting controls, or auditing matters,
promptly report them to Corporate Audit or the OEC.
Abbott Quality and Regulatory – If you have questions about the

quality and safety of our products, contact your local Quality and
Regulatory department.
Global Environmental Health and Safety – Contact a Global

Environmental Health and Safety representative if you have
questions about a physical site and potential dangers.
Global Purchasing Services – If you have questions about supplier

relations, contact Global Purchasing Services.

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Code of

PAGE 2 ABBOT T CODE OF BUSINE SS CONDU C T

brand by holding fairness, and integrity.

PAGE 3 ABBOT T CODE OF BUSINE SS CONDU C T

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It is up to every person working for

PAGE 6 ABBOT T CODE OF BUSINE SS CONDU C T

Colleagues Learn more about the different

The Legal Division

PAGE 7 ABBOT T CODE OF BUSINE SS CONDU C T

We must recognize the global impact

PAGE 8 ABBOT T CODE OF BUSINE SS CONDU C T

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We prioritize the health and well-being

We respect the expertise of health care

PAGE 10 ABBOT T CODE OF BUSINE SS CONDU C T

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We produce and deliver safe, Learn more about our products:

PAGE 12 ABBOT T CODE OF BUSINE SS CONDU C T

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We promote our products for the

WHAT IS ABBOTT’S POLICY

PAGE 14 ABBOT T CODE OF BUSINE SS CONDU C T

PAGE 15 ABBOT T CODE OF BUSINE SS CONDU C T

We innovate and advance health care

We foster a culture of innovation,

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We conduct research to obtain and

PAGE 17 ABBOT T CODE OF BUSINE SS CONDU C T

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We foster a culture of openness,

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We ask questions whenever choices or

PAGE 20 ABBOT T CODE OF BUSINE SS CONDU C T

Refusal to cooperate in the investigation

Failure by a violator’s supervisor(s) to detect

Reporting a concern that is knowingly false,

Retaliation, such as by intimidating, threatening,

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We provide equal opportunities

We strive to ensure that everyone

PAGE 23 ABBOT T CODE OF BUSINE SS CONDU C T

We treat everyone with Learn more about our

We take care to ensure workplace Learn more about our

Accidents and unsafe situations must be promptly reported

PAGE 24 ABBOT T CODE OF BUSINE SS CONDU C T

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We strive to foster community well-being

We encourage appropriate engagement

PAGE 26 ABBOT T CODE OF BUSINE SS CONDU C T

We engage in sustainable development

PAGE 27 ABBOT T CODE OF BUSINE SS CONDU C T

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We conduct business ethically and

We address and resolve any conflicts

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orporate OEC – Call 1-224-667-5210 or email