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Ethics and Compliance

BD is committed to creating an environment in which all associates feel comfortable raising concerns, seeking guidance, or asking questions without fear of retaliation or discipline.

Except as prohibited by applicable law, BD associates are obligated to report any suspected violations of laws, industry codes, the BD Code of Conduct, or BD policies in accordance with the BD Global Speaking Up Policy.

Anyone can seek guidance or report ethics concerns in a number of ways, including the BD Ethics Helpline or via email. The Helpline is independently operated and available anywhere in the world 24 hours a day, 7 days a week. The Helpline can be reached by telephone or online. The Helpline provides translation services as needed, and reports can be made anonymously where permitted by law. BD associates can also report violations to their supervisor, management, Human Resources, the Law Group or directly to Ethics & Compliance.

BD takes all reports of violations of laws, BD policies, and ethical standards seriously and will promptly, fairly, and thoroughly investigate all such reports. BD does not tolerate any form of retaliation against any person who in good faith reports an actual or suspected violation or cooperates in BD investigations.

The BD Code of Conduct sets the foundation for how we behave at BD. Our value “We do what is right” is the cornerstone of our Code. To do what is right, we follow the laws, rules, and company policies that apply to us. We also follow the highest ethical standards, even when there’s no specific law or policy. Our Code provides guidance and resources to help us follow through on these ethical standards and protect our reputation.

Everyone at BD—from directors to officers and associates—must follow our Code. It applies equally to everyone, no matter their position or level. BD associates receive information and training about the Code, and other policies in several ways, including periodic communications and trainings. Associates can access detailed information on our expectations through our intranet and on our ethics and compliance mobile app.

BD Code of Conduct

We work in the most dynamic and consequential industry in the world. The products we make today are a vital part of the global healthcare system,
and we have the capability to change even more lives in the future as we work together to fulfill our Purpose of advancing the world of health™.

Our Purpose comes with enormous responsibility, and how we deliver on this promise is just as important as what we ultimately accomplish. The answer can be found in The BD WAY the values, mindset, and leadership commitments that surround our Purpose and in one value in particular: "We do what is right." This is the foundation of our Code of Conduct, which guides every decision we make, every action we take, and every interaction we have with our customers, our business partners, our communities, and each other. This includes speaking up when we have concerns and seeking help when we have questions.

Our Code of Conduct provides direction on how we must behave in any scenario, and it applies to all of us, equally. Nothing is more essential to our success than doing the right thing; by familiarizing yourself with the Code of Conduct, you'll be taking an important step in helping us fulfill our Purpose and potential the right way-The BD WAY.

—

Tom Polen, Chairman, CEO and President

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At BD, we are committed to a strong ethics and compliance culture. We do not tolerate actions or behaviors that are inconsistent with our values or violate the BD Code of Conduct or applicable laws and regulations. All BD associates are responsible for reinforcing our ethics and compliance culture and sustaining our reputation as a company dedicated to quality and integrity. We encourage and expect everyone at BD to speak up by asking questions, raising concerns, seeking guidance, and reporting actual or suspected violations of laws, our Code of Conduct, our policies, or our high ethical standards. This requirement extends to all associates, vendors, and other third parties working on our behalf.

The BD Values further strengthen our culture of ethics and compliance and guide how we hold ourselves accountable to our shareholders and stakeholders.

We do what is right.
We thrive on innovation and demand quality.
We are all accountable.
We learn and improve every day.
We help each other be great.

Under the oversight of the Audit Committee of the Board of Directors, BD’s global Ethics & Compliance function seeks to ensure that BD has a comprehensive compliance program that is designed to prevent and detect wrongdoing and continuously encourages lawful and ethical conduct. Senior Vice President, Chief Ethics, Compliance & Privacy Officer leads the global Ethics & Compliance function and along with the BD Ethics & Compliance Committee, which is comprised of members of BD’s executive leadership team, oversees these activities to ensure effective operation and enforcement of BD’s global Ethics & Compliance program. The program is integrated into our global business operations. We evaluate the effectiveness of our program and adapt it periodically to ensure it is appropriately tailored to address the risks inherent in our global business.

Acting with integrity is critical to ensuring our success and protecting our reputation as we strive to advance the world of health. Associates and external business partners must conduct their activities in full compliance with all applicable antibribery and anticorruption laws, including local laws and industry codes in the countries where BD operates, as well as laws with cross‐border implications such as the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act.

Strong, long-term relationships with healthcare professionals (HCPs), healthcare organizations (HCOs), and government officials (GOs) help us better understand our customers and their patients’ needs. Through collaboration, we continue to develop high-quality products and teach people about their safe and effective use. These relationships must be based on the highest ethical standards. We must ensure that such interactions do not involve bribery, corruption, or other improper behavior. For these reasons, we do not offer, promise, provide, authorize, or accept improper payments, and we record all payments accurately. It’s critical that we avoid even the appearance of trying to bribe someone.

The Ethics & Compliance function provides resources to regional and local country management to enhance their anticorruption and compliance business practices. This includes incorporating compliance requirements into existing business practices and advising local management on anticorruption compliance-related issues.

BD holds the value that “We do what is right” and is fully committed to upholding the highest ethical standards set forth by all government regulatory bodies and all industry codes surrounding conduct engaging HCPs and HCOs.

We comply with all applicable laws and regulations that govern the interactions between medical technology companies and healthcare professionals, healthcare organizations and government officials in the many countries in which we do business.

In addition to our Code, BD has a set of global policies and standards, including our Global Standards for Interactions with Healthcare Providers, Health Care Organizations and Government Officials, which are designed to provide associates clear guidance on how to do what is right in the context of their work for BD.

BD has also adhered to various industry codes, including those of AdvaMed, APACMed, MedTech Europe, Mecomed, and ABIMED.

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