VOICE YOUR CONCERN
POLICY
OFFICE OF ETHICS & COMPLIANCE | OEC – PR1 | VERSION 3 | EFFECTIVE 16-FEB-2011
This policy clarifies how and why employees and anyone acting on behalf of Medtronic must
voice their concerns by speaking up about potential wrongdoing. It also addresses potential
concerns about retaliation. The policy promotes a “culture of ethics and compliance” as an
integral part of our commitment to fulfill the Medtronic Mission by being recognized as a
company of dedication, honesty, integrity, and service.
STATEMENT OF MEDTRONIC POLICY:
Medtronic expects our employees and those acting on the company’s behalf to voice concerns
and report non-compliance with the law, our Code of Conduct and stated company policies,
including local Business Conduct Standards. Medtronic prohibits retaliation against anyone for
raising a concern or reporting suspected misconduct in good faith.
1. WHAT DOES THIS POLICY COVER?
This policy covers any situation in which an employee, the company itself, or someone acting on
its behalf may be engaged in improper conduct. This policy requires immediate reporting of
“significant” ethics or compliance matters. A “significant” ethics or compliance matter is any
situation which may:
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Be potentially illegal; for example affect accuracy of the company’s financial records or
violate criminal, civil, or administrative laws which prohibit fraud or kickbacks in
connection with a government healthcare program;
Violate our Code of Conduct or stated company policies, including local Business
Conduct Standards;
Expose Medtronic, its employees, officers or directors to liability;
Damage the reputation of Medtronic; or
Require immediate attention.
This policy does not cover reporting employment concerns that are not legal or policy violations.
Other channels are available for these types of concerns, beginning with your manager or local
Human Resources representative.
2. WHO MUST FOLLOW THIS POLICY?
If you see, hear, or otherwise learn about improper conduct, you must speak up. This basic rule
applies to everyone who works for, or on behalf of, Medtronic anywhere in the world.
3. WHAT ARE MY RESPONSIBILITIES?
Every person acting on Medtronic’s behalf is responsible for upholding the Medtronic Mission,
our Code of Conduct, Business Conduct Standards and applicable company policies. You do
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this by knowing and following the ethical and legal requirements that apply to your job, but also
by speaking up if:
• You are unsure about the proper course of action and need advice about an ethics or
compliance concern;
• You believe that someone acting on behalf of Medtronic has done, is doing, or may be
about to do something that violates the law, our Code of Conduct, local Business
Conduct Standards or company policy;
• You believe that you yourself may have been involved in misconduct when doing
something on behalf of Medtronic.
In addition, Medtronic expects you to:
• Never discourage others from reporting a problem;
• Always report your concerns in good faith – never knowingly make a false report;
• Give due regard to protecting the rights and concerns of anyone accused of misconduct;
• Be truthful, candid, and cooperative in any internal inquires; and
• Never retaliate against an employee who makes a report.
4. WHAT IF I NEGLECT OR ABUSE MY REPORTING RESPONSIBILITIES?
If you fail to report misconduct you know about, you are violating a key requirement of our Code
of Conduct and may be subject to disciplinary action. Be aware, however, that if you abuse the
reporting system and knowingly submit a false report, you will automatically become the subject
of a separate investigation and, if substantiated, you will definitely face disciplinary action.
5. HOW DOES MEDTRONIC PREVENT RETALIATION?
Any employee who seeks advice in good faith and raises a concern or reports suspected
misconduct is doing the right thing. Medtronic will not tolerate retaliation against that person.
Anyone who engages in retaliatory action will face discipline, which may include any form of
discipline up to and including termination, regardless of that person’s position or stature within
the company. If you believe that you or someone you know has been retaliated against for
raising an ethical or compliance-related issue, immediately contact the Voice Your Concern
Line; a business unit/geography’s compliance leader; Medtronic legal counsel; a human
resources representative; or Tom Schumacher, the Medtronic Chief Ethics & Compliance
Officer. Directions for how to obtain advice or report a concern are included below.
6. WHERE CAN I ASK QUESTIONS?
No company can anticipate all the situations and circumstances its employees and others may
face. If you have questions about a Medtronic policy or a situation you think is not covered by a
policy, ask for clarification. You can get help or advice from:
• Your manager
• Your local Human Resources representative
• Your business unit/geography’s compliance leader
• Your assigned Medtronic legal counsel
• The Voice Your Concern Line: call 1-800-488-3125 or click VoiceYourConcernLine.com
• The Medtronic Office of Ethics & Compliance
- Email: rs.ethicsandcompliance@medtronic.com
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- Call: (763) 505-2050
- Write: Medtronic Office of Ethics & Compliance
710 Medtronic Parkway, MS LS 320
Minneapolis, MN 55432-5604
7. WHAT ARE EXAMPLES OF COMPLIANCE CONCERNS THAT I AM
REQUIRED TO REPORT?
No matter where you work in the company, you have an obligation to report suspected
misconduct so that Medtronic can quickly take corrective action. Here are a few examples of the
types of issues you must report:
• Benefits offered or given to a customer to encourage or reward the purchase of products
(such as bribes or kickbacks)
• Bribery or attempted bribery of government officials, customers or others
• Material misrepresentation within documents submitted to a government entity,
particularly in applying for benefits from any government healthcare program
• Medtronic promotion of products for unapproved (off-label) uses (not including routine
product technical support when, in the interest of patient safety, a physician has
determined to make an unapproved use of a Medtronic product)
• Probable violations of criminal, civil, or administrative laws applicable to any U.S. federal
healthcare program for which penalties or exclusion may be authorized
• Any U.S. government investigation or legal proceeding alleging Medtronic has
committed a crime or engaged in fraudulent activities
• Any ineligibility of a Medtronic employee or someone acting on its behalf to work with
U.S. federal government programs because of misconduct
• Breaches of protection of personal identifying information (for example, patient personal
health information)
• Exchange of pricing or other proprietary information with competitors or other anticompetitive behavior
• Misuse of Medtronic funds, including theft, fraud, and embezzlement
• Inaccurate creation, reporting or falsification of company business and financial records
or regulatory submissions
• Intentional misstatement of accounting records
• Improper booking/accounting of sales revenue or expenses
• Falsification of expense reports (including intentional acts of omission)
• Falsification of research, development, production, or product quality data
• Violations of our Code of Conduct or stated company policies, including local Business
Conduct Standards
• Deliberate or willful attempts to circumvent company policies, procedures or controls
• Retaliation against any employee disclosing an ethics or compliance concern
• Unsafe work practices
• Workplace violence
• Discrimination or sexual harassment
• Any non-compliance with product quality requirements
• Unauthorized disclosure of Medtronic intellectual property or confidential information
• Undisclosed conflicts of interest between a Medtronic employee and a competitor,
supplier or customer
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•
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Receiving any kickback from a Medtronic supplier/vendor of products or services
Accepting or giving impermissible gifts
8. WHOM SHOULD I CONTACT TO VOICE A CONCERN?
Where to raise a concern depends in some degree on the nature of the issue and the people
involved. Typically, the best place to raise an issue is within your own department or business
unit. In most cases, your manager, your local Human Resources representative, or your
business unit/geography’s management is closest to the issue and may be the best place to go
to respond quickly. If you are uncomfortable reporting an issue within your business unit, or
local reporting does not make sense based upon the nature of the issue or people involved,
other options include:
• A business unit or geography compliance leader
• Any Medtronic legal counsel
• The Voice Your Concern Line: call 1-800-488-3125 or click VoiceYourConcernLine.com
• The Medtronic Office of Ethics & Compliance
- Email: rs.ethicsandcompliance@medtronic.com
- Call: (763) 505-2050
- Write: Medtronic Office of Ethics & Compliance
710 Medtronic Parkway, MS LS 320
Minneapolis, MN 55432-5604
• Independent directors on the Medtronic Board at independentdirectors@medtronic.com
• The lead director of the Medtronic Board at leaddirector@medtronic.com
The Voice Your Concern Line website, telephone number and individual country codes are
available on the last page of this policy, on the Office of Ethics & Compliance website and
printed on inserts to our Code of Conduct. Once you make the call, you will be connected to a
Voice Your Concern Line representative who will listen to your concerns and report them to the
Chief Ethics & Compliance Officer. The Voice Your Concern Line operates in compliance with
local laws and provides translators for you if needed.
9. WHAT IF I WANT TO REMAIN ANONYMOUS?
Face-to-face discussions are often best, but there may be times when you may not feel
comfortable talking to someone in person or you may prefer to remain anonymous. That is why
the Voice Your Concern Line is available online and by telephone toll-free. It allows you to
report your concerns anywhere, anytime, completely anonymously. The Voice Your Concern
Line website is hosted by an independent third party, so you do not need to have access to the
Medtronic internal network to submit your report. All calls and electronic web reports are
caller/user-identification blocked, allowing you to remain anonymous if you prefer.
10. WHAT SHOULD I DO IF SOMEONE COMES TO ME TO REPORT
POSSIBLE COMPLIANCE OR ETHICAL CONCERNS?
If someone comes to you with an ethics or compliance concern, you are expected to
immediately inform your manager unless the suspected misconduct concerns him or her
directly. If you are uncomfortable reporting an issue locally, or if local reporting does not make
sense based upon the nature of the issue or people involved, you may report to any business
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unit or geography compliance leader, any Medtronic legal counsel, or the Medtronic Chief Ethics
& Compliance Officer.
If the reported concern is a significant ethics or compliance matter, the person who receives the
concern or report will determine whether the matter should be forwarded to the Medtronic Chief
Ethics & Compliance Officer, who will, in turn, determine who should be involved in the
investigation and how it should be conducted.
11. WHAT IF I AM NOT SURE I WANT TO VOICE A CONCERN?
Raising concerns can be hard. Sometimes people are reluctant to raise concerns because they
are afraid they will be retaliated against. This should not prevent you from raising a concern at
Medtronic. Medtronic strictly prohibits retaliation against anyone for raising a concern or
reporting suspected misconduct in good faith. If you are concerned you have been or will be
retaliated against for making a report, you should contact the Medtronic Office of Ethics &
Compliance.
Another reason people do not want to make a report because they do not want to get anyone in
“trouble.” This is a mistake. Prompt reporting of concerns can stop a small problem from
becoming a big problem – not only for the individuals involved, but for you, your business unit,
and in a very real way, the company. In fact, the consequences of failing to correct a known
problem are oftentimes far worse than the consequences for the problem itself.
Lastly, people may not raise concerns because they believe nothing will happen. Medtronic is
committed to responding to employees who raise a good faith concern about a potential issue.
To protect the privacy of those involved, however, we may not always be able to share the
outcome of an investigation with employees. If you have reported a concern locally to
management and feel the situation was not resolved, you should escalate the issue to higher
management, contact the Office of Ethics & Compliance, or submit your report and concerns to
the Voice Your Concern Line.
12. WHAT HAPPENS WHEN I MAKE A REPORT?
Medtronic takes all reports seriously. All reports are reviewed to determine if the matter should
be investigated and, if so, how best to investigate and resolve the matter, based on the nature
of the report. A person is never presumed to be “guilty” based on a report without further
investigating the matter. The facts are investigated to determine objectively what happened and
decide what to do based on those facts. The requirements for conducting an investigation are
clear. Any investigation should be:
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Impartial,
Competent,
Honest and fair,
Timely,
Thorough, and
Confidential.
The Chief Ethics & Compliance Officer may consult other senior executives including the
Medtronic General Counsel to determine if further reporting to the Medtronic Board of Directors
or other parties is warranted.
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13. WILL YOU KEEP MY REPORT CONFIDENTIAL?
The company will handle all reports with discretion and, at your request, will protect your
confidentiality. Obviously, certain individuals have to know the circumstances about the report
and the specifics of the allegation for effective investigation and follow-up. Also, there may be
times when Medtronic has a legal obligation to make available to third parties information about
reported compliance issues. In these situations, your identity may become known during the
course of the investigation. If this occurs, Medtronic will strive to keep your identity confidential
and prevent any retaliation based upon the report.
14. WHAT WILL MANAGEMENT DO ABOUT MY CONCERNS?
Each case is unique, but we use a consistent process. We may determine that we do not need
to take action or, at the other end of the spectrum, we may need to self-report to the
government. If the facts warrant, management will take corrective action to improve business
systems or take disciplinary action against employees who have broken the law or violated
company policy, including our Code of Conduct and local Business Conduct Standards. Such
discipline may include any form of discipline up to and including termination. In some cases we
may report matters to law enforcement authorities for possible prosecution.
15. WILL I BE TOLD ABOUT THE DETAILS OF AN INVESTIGATION OR
ITS OUTCOME?
In most cases, you will be told whether your reported issue was investigated and whether it was
resolved. You should know that there are legal and other restrictions on what information
Medtronic is allowed to provide. For example, you will not be told about the actions taken
against an employee as a result of your report because that information may be considered
“private” under applicable law. You also will not be told information that is considered to be
legally privileged or otherwise confidential. If you report the concern anonymously, you will not
be told about the status of an investigation, unless you did so using the Voice Your Concern
Line.
16. WHAT IF I BELIEVE THAT I MAY HAVE BEEN INVOLVED IN
CONDUCT THAT VIOLATES THE LAW OR COMPANY POLICY?
All employees of Medtronic and those acting on its behalf are expected to know and follow the
laws and company policies applicable to their jobs. In most cases, standards are violated due to
ignorance or mistake, not deliberate and premeditated misconduct. While all allegations need to
be reviewed and appropriately redressed, we will look at the facts of each incident to ensure fair
treatment, including the reasons for a violation, good faith of the people involved, and timeliness
of corrective action. In many ways, not reporting a violation once you become aware of it is
more serious than the violation itself. If you believe you may have violated a law or policy, the
best course of action is to raise the issue and get it resolved.
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17. WHAT IF I REPORT SOMETHING TO MY MANAGER AND I’M TOLD
TO “KEEP QUIET” ABOUT IT?
If you think that you are being discouraged from reporting a potential violation of the law or
company policy, you should report both the original concern and the fact that you have been
told to “keep quiet.” You can do so either to your business unit/geography’s compliance partner,
your assigned Medtronic legal counsel, the Medtronic Chief Ethics & Compliance Officer, or
through the Voice Your Concern Line.
18. HOW CAN I LEARN MORE?
The Medtronic Code of Conduct, Business Conduct Standards and False Claims Awareness
Information for Employees are available through the Medtronic Office of Ethics & Compliance
intranet site at EthicsAndCompliance.medtronic.com
For questions about this policy, contact the Medtronic Office of Ethics & Compliance.
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VOICE YOUR
CONCERN LINE
A risk-free, voluntary way to report
activities that may involve criminal
conduct or noncompliance with the
Medtronic Code of Conduct.
VoiceYourConcernLine.com
1-800-488-3125
(U.S., Canada, and Puerto Rico)*
Toll-free, 24 hours a day.
If you prefer, call anonymously.
Your name is not required.
* TO USE THE VOICE YOUR
CONCERN LINE
OUTSIDE THE U.S.:
• Dial the access code for the
country you are in.
• Wait for an operator or an
English-language prompt.
• Dial 800-488-3125
The Voice Your Concern Line operates in
compliance with local law.
Medtronic Confidential
Country:
Access Code:
Argentina
0-800-555-4288
or 0-800-222-1288
1-800-551-155
0-800-200-288
0-800-100-10
000-8010
1-800-225-5288
10811
0800-22-01-11
8001-0010
0-800-110-015
0800-99-00-11
0800-2255-288
00-800-1311
800-96-1111
000-117
1-800-550-000
1-800-94-94-949
or 1-800-92-22-222
or 1-800-93-33-333
172-1011
KDDTelecom: 005-39-111
IDCT Telecom: 0066-55-111
0030-911
In Beirut: 426-801
Outside Beirut: 01-426-801
01-800-288-2872
or
001-800-462-4240
0800-022-9111
800-190-11
800-0111-111
0-800-99-0123
900-99-00-11
020-799-111
0-800-89-0011
0800-89-0011 or
0500-89-0011
Australia
Austria
Belgium
Brazil
Canada
China, PRC
Croatia
Denmark
Finland
France
Germany
Greece
Hong Kong
India
Ireland
Israel
Italy
Japan
Korea, Republic of
Lebanon
Mexico
Netherlands
Norway
Singapore
South Africa
Spain
Sweden
Switzerland
United Kingdom
Public phones require coin or card deposit
AT&T Direct calls cannot be placed to this country from
outside the U.S.
May not be available from every phone/public phone
Not available from public phones
Collect calling only
Available from phones with international calling capabilities
or from most Public Calling Centers
Public phones require local coin payment through the call
duration
When calling from public phones, use phones marked
“Ladatel”
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