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Bio-Rad iCode Introduction.mp4
Frequently Asked Questions
Our Speak Up Culture
Asking Questions and Raising Concerns
A: Our Bio-Rad Integrity Helpline allows you to report anonymously except in very specific locations where local law does not allow anonymous reporting.
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A: You do not need to decide or be certain about whether conduct violated our Code, our policies, or the law. You only need to have a question or a suspicion about the conduct for Bio-Rad to investigate.
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A: No. We all share a duty to report our concerns regardless of whether the misconduct in question affects us personally, whether others have observed it, or even if we think it might have been reported already. You may have information no one else has provided, and we want everyone to be ready to come forward and make reports or ask questions whenever they have concerns.
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Compliance with the law
A: You follow the more restrictive provision, whether it is in our Code or the local Bio-Rad policy, and you seek advice from the Legal Department or the Compliance Department.
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A: Yes, it is wrong because these payments, called “facilitation payments,” are a violation of the law that applies to Bio-Rad. In general, whenever a local business practice or custom violates a law that applies to Bio-Rad, you must follow the more restrictive requirement. Seek advice from the Legal Department or the Compliance Department any time.
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Cooperation with Investigations
A: No. Some cases, depending on the subject matter, are handled by Human Resources. The Corporate Compliance Department and Human Resources work together, using pre-defined criteria, to determine which team conducts the investigation.
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A: No. Do not conduct your own investigation. If you are aware of potential misconduct, then you should immediately report it to your manager or Human Resources or through the Integrity Helpline.
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A: Yes. Everyone must cooperate with internal company investigations, including fully and honestly providing all the pertinent information we have. Your cooperation helps ensure any investigation is thorough and complete. Also know that any retaliation due to your participation in an investigation will not be tolerated.
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A: No. Punishing an employee for using the Bio-Rad Integrity Helpline or cooperating with an investigation is strictly unacceptable, and any person engaging in retaliation is subject to discipline, up to and including termination. Examples of retaliation include demoting, giving poor evaluations, disciplining, reassigning, reducing pay, or even terminating employment.
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Higher Expectations for Supervisors and Managers
A: Yes. As a supervisor, you are the most important compliance resource your workforce members have. You are both the conduit for valuable information about the risks we face as an organization and a channel that workforce members can use to ask questions and report any concerns. You should not only act ethically but also explain to your team what you are doing and why.
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A: No. That would be violation of policy. Failing to get the proper approvals violates Bio-Rad policy, which is to ensure that adequate internal accounting controls are maintained and operating effectively. As a supervisor, not only must you follow and model the rules, but you cannot pressure your team to violate those same rules.
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No Retaliation
A: Our Bio-Rad Integrity Helpline is available to you, if you want to report anonymously or you fear reporting to your local manager or leadership. You can also reach out directly to our Corporate Compliance Department.
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A: Retaliation can appear in many forms and from many sources. Some typical examples include retaliation by colleagues, by a manager, or by the overall organization.
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A: As noted in the Key Terms section, it can help to think of retaliation as falling into two types. Both types are unacceptable and can have serious negative consequences. The two labels sometimes used are “hard” and “soft” retaliation.
Examples of “Hard” retaliation can include:
- Reduction in pay, bonus, and/or benefits
- Change in shifts/hours
- Unwarranted negative evaluation
- Demotion, bad assignments, or loss of position
- Dismissal/firing or unfair disciplinary action
- Physical harm to property or person, whether actual or perceived
Examples of “Soft” retaliation can include:
- Lack of support
- Loss of responsibilities
- Loss of status
- Loss of overtime allocations/opportunities
- Being left out, shunned, cut off, subject to the “silent treatment”
- Avoidance
- Undesirable assignments
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A: It is understandable that you would be concerned. However, it is prohibited to launch reprisals, retribution, threats, or retaliation against a person who has in good faith reported a violation or a suspected violation of law, this Code or other company policies, or against a person who is assisting in good faith in any investigation or process with respect to such a violation.
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Violations of Our Code
A: No. We must obey the law, our Code, and our policies regardless of any instructions from our manager or other leaders. Our obligation to follow the rules is greater than any obligation to follow orders. You should report any such issue immediately. You can also reach out directly to our Corporate Compliance Department.
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A: You should ask your manager, supervisor, Human Resources Department or other channels identified in the Asking Questions and Raising Questions section of the Code, or you may ask the question through the Bio-Rad Integrity Helpline at www.Bio-RadIntegrityHelpline.com. Our Integrity Helpline is available to Bio-Rad workforce members, officers, directors, business partners, and other third parties, except where prohibited by local law.
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A: Bio-Rad encourages you to report suspected violations of the law of the Code, and we prohibit retaliation against anyone who, in good faith, reports a violation of the Code or cooperates in an investigation. This is true regardless of whether the underlying report is found to be correct or results in corrective action. If you feel that you have been retaliated against, you can report this through the Helpline or through other resources identified in the Asking Questions and Raising Concerns section of the Code.
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A: You can trust the Bio-Rad investigation process to be consistent, fair, and prompt. Investigations are carried out by trained personnel using the Bio-Rad standard protocol. Investigations are conducted by either the Corporate Compliance Department or HR, with support from Legal and other experts as appropriate. You should not “investigate” matters yourself.
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A: You should report the issue through the Integrity Helpline at www.Bio-RadIntegrityHelpline.com.
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A: If you suspect illegal action or activity, you should report it or talk with your manager or supervisor about it. Bio-Rad counts on you to exercise high ethical standards and good judgment at all times, whether or not an issue is specifically addressed in the Code. No code of conduct can address every situation; you are responsible for abiding by the policies in place at your work site and understanding the laws applicable to your job.
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Maintaining Integrity for Our Company and Our Stockholders
Avoiding Insider Trading
A: No. Our insider trading policy and the law forbid trading on any information, whether it is regarding Bio-Rad’s or any other company’s securities. It doesn’t matter that the information doesn’t apply to your work or that the stock purchase in question doesn’t involve Bio-Rad securities.
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A: No. We never provide any material, non-public information to anyone not authorized to have it.
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Charitable Contributions and Community Impact
A: Not without obtaining management approval and submitting a request through the Bio-Rad Business Courtesies Portal. Any contribution must be reasonable, not meant to improperly influence any business decision, and otherwise compliant with all applicable laws.
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A: Not without pre-approval. Contact Human Resources to find out the criteria and process for getting official approval for such activities.
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Data Privacy
A: The Bio-Rad global Data Protection Officer is the Chief Compliance and Privacy Officer, Matt Werner. Contact the Data Privacy Office via [email protected] for further details.
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A: Yes. Please contact the [email protected] for further details.
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A: No. Because you lost control of the file, this is still a breach, so you must immediately report it to our Chief Privacy Officer at [email protected], the Compliance Office at [email protected], or the Integrity Helpline.
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A: Yes. Please use the Tender Response Data Protection and Information Security FAQ. It has more than 15 pages of questions and answers to help you with the standard data privacy questions that tenders often contain.
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Internal Controls
A: No, that’s not correct. People at every level of an organization are responsible for internal controls, whether those controls are financial controls, operational controls, or regulatory controls. For example, our policies and procedures, which direct how all employees are to perform their duties, are a type of internal control that helps to ensure tasks are performed correctly and consistently.
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A: To help ensure regulatory compliance, reliability of financial reporting, and the effectiveness and efficiency of operations, employees should seek to understand the internal controls that apply to their roles as well as the risks those internal controls are intended to mitigate. If you do not know what the internal controls are in your area, ask your manager. To ensure internal controls are being performed effectively, refer to the relevant policies and procedures or standard operating procedures (SOPs) provided by management.
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A: Discuss this matter with your manager, your Quality Assurance team, or, in the case of a finance-related control, the Controls Compliance team.
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Political Activities
A: No. It is against our policy to use company time, funds, or resources for any political cause or candidate. Even if the cause has nothing to do with our business, we still do not use Bio-Rad’s resources or time for personal political activity.
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A: No. We cannot suggest or imply in any way that we speak on behalf of Bio-Rad on any political matter or concern. We also cannot use Bio-Rad resources, such as email accounts or telephones, in any effort related to a political issue.
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Information Security
A: Yes. Immediately report the incident to the Bio-Rad Service Desk, since you may have compromised your laptop and possibly our network.
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A: No. Microsoft does not call users and Bio-Rad maintains its own computers. This is a common scam that could result in a data breach. Phone calls are difficult to trace, so as long as you did not comply with the caller, you’re fine. If you did anything that the caller asked, contact the Bio-Rad Service Desk to have your computer cleaned and checked
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A: No. Do not plug unknown drives or devices into your computer, as this is a common method of installing malware on your computer. If you did not plug it in, it should be disposed of as soon as possible. If you did plug it into your computer, contact the Bio-Rad Service Desk to have your computer checked and cleaned.
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A: Unfortunately, it’s easy for cyber criminals to make an email look like it came from someone else. Ask yourself if your job role is one where a request like this might happen. If there are any doubts, don’t comply and contact the privacy hotline.
Also, here are a few reminders on ways to spot phishing attacks:
- Always be vigilant. It’s human nature to trust and want to help others. Cyber criminals know this and use it to their advantage.
- If an email is delivered to your spam folder, there is a reason it was identified as suspicious.
- Hover over the sender’s name to see if the email name in the pop-up window matches the sender’s name. Cyber criminals can impersonate Bio-Rad executives as well as colleagues, friends, and family. Always check to be sure.
- Watch for “trick” addresses. [email protected] is not the same as [email protected] (in the first address, the “I” in Bio-Rad is actually a lower case “L.”)
- Ask yourself “why would this person ask me to do this?” This is especially true if you feel pressured to do something quickly. Take a moment to think it through. If it sounds too good to be true, it probably is.
- Finally, if you suspect you’ve been targeted by a phishing attack:
- Don’t open any attachments.
- Click on the three vertical dots next to “Reply” and select “Report phishing” so we can improve our filtering.
- Contact the Service Desk (biorad.service-now.com/ess) so the personnel there can assist in gathering pertinent information for Information Security to investigate.
- Delete the email.
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Protecting Intellectual Property
A: You should describe the idea to your supervisor and submit an invention disclosure via the IPFolio Inventor Portal. Your invention disclosure will be discussed at your group’s next patent committee meeting to determine next steps.
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A: No. You should report any unapproved use of our logo, or any other trademarks or IP, to the Legal Department.
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Preventing Money Laundering
A: Yes. You should be concerned if a customer’s transactions are odd or unusual. If you see such activity, you should immediately inform your manager and contact the Corporate Treasury Department or our Bio-Rad Integrity Helpline.
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A: Yes. You should be concerned if customers ask for transfers or make “add payment” requests. If you see such activity, you should immediately inform your manager and contact the Corporate Treasury Department or our Bio-Rad Integrity Helpline.
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A: Yes. You should be concerned if a customer does not provide all the information you expect. If you see such activity, you should immediately inform your manager and contact the Corporate Treasury Department or our Bio-Rad Integrity Helpline.
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Protecting the Environment
A: No. Even if a supervisor or manager suggests something is okay or directs an employee to dispose of waste in such a manner, it is still your duty to speak up when you observe a possible violation of our policy or the law. You can contact one of the resources in our Code, or you can raise a concern through the Integrity Helpline.
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Records and Information Management
A: No. We must not follow any order that would cause us to violate our Code, our policies, or the law. If your manager instructs you to do something against our Code, our policies, or the law, seek help from the other resources described in our Code including the Bio-Rad Integrity Helpline.
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A: We have a Vital Record Security and retention schedule that determines how long employees should keep the records in their care. While the specific retention policy and schedule can vary by department and type of record, its overall purpose is to:
- Ensure the integrity, security, and availability of information needed for Bio-Rad’s records and information management activities;
- Comply with applicable laws and regulations that prescribe minimum and maximum time periods for retention of certain records;
- Preserve and retain records that are necessary for the protection of Bio-Rad’s legal rights;
- Support the efficient retrieval, transfer, and storage of records; and
- Provide for the proper destruction of records that are no longer required.
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A: Yes, according to Bio-Rad’s record retention policy and schedule, it is the expectation and policy that all Bio-Rad workforce members, vendors, and contractors comply with the terms of the policy and applicable law at all times.
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A: We are committed to enforcing this policy as it applies to all records, and the effectiveness of Bio-Rad’s efforts depends largely on its individual members – us. If inappropriate conduct is not reported, Bio-Rad may not be able to take appropriate corrective action.
If you believe in good faith that you or someone else may have violated this policy, please report the incident immediately. No one will be subject to any form of discipline, reprisal, intimidation, or retaliation for reporting incidents of inappropriate conduct of any kind or for cooperating in related investigations.
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External Communication
A: No. The company must keep a consistent voice when speaking externally. If you are not authorized to speak on behalf of Bio-Rad, then do not do it. You can report posts on social media and other public statements that you think should be addressed to Corporate Communications.
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A: No. Unless you have been specifically authorized to speak to the media on Bio-Rad’s behalf, you should refer her to Corporate Communications.
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Maintaining Integrity in the Workplace
We Foster an Inclusive and Positive Work Environment
A: No. Harassing behavior creates a negative work environment, so it does not matter whether or not the behavior is directed at you. If you know of potential harassment, you must report it immediately.
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A: No. We do not discriminate based on criteria such as age. When we are making employment decisions, we consider only an applicant’s qualifications for the role.
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A: We must always follow safety rules and procedures and never disregard them. If there is ever an issue with faulty or broken safety equipment, you should raise it with your manager immediately.
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Leaders Engage Their Teams in Communication About Integrity
A: Leaders must make sure that business or commercial goals never interfere with the obligation to adhere to our shared values and follow our Code, our policies, and the law at all times. Business goals cannot supersede integrity. Leaders and workforce members may have to think creatively to meet goals, but they must always work with our values in mind while following our Code, our policies, and the law.
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A: While the wisdom of following the law, our Code, and our policies might seem obvious, when workforce members see and hear priority put solely on commercial goals, for example, they may feel that leaders do not value acting with integrity if it seems to interfere with those goals. Therefore, we all must be very vocal and clear that exercising ethical decision-making and integrity is always the most important goal.
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Maintaining Integrity with Our Customers and Business Partners
Anti-Corruption Compliance
A: No. We must be careful when we provide anything of value, including travel and accommodations, to potential clients and other business partners. We never provide travel for family members. In this case, it is possible that the purchasing manager is a government official, since hospitals can be state-owned. Before you agree to such expenses, particularly in the case of government officials, you must discuss the situation with the Compliance Department and get approval.
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A:
- We are doing business in a country that has a reputation for corruption.
- A Bio-Rad agent or subcontractor asks for an unusually large or contingent fee.
- We are asked to make payment to another person, in another country, or to a numbered bank account, or to pay in cash.
- A Bio-Rad agent has a family or business relationship with a public official.
- A healthcare entity asks us to make a political or charitable contribution or to use a particular subcontractor.
- A Bio-Rad agent asks for an increase in the agreed-upon fees to close the deal.
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Assuring Product Quality and Safety
A: You should raise the issue with your supervisor. You should not proceed with using the machine until the issue has been reviewed with QA and documented, and a decision has been made regarding control of the affected product pending the recalibration.
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A: No. GMPs and other regulations must be adhered to completely. If you have a suggestion for a change, inform your manager, but we cannot simply ignore GMPs that apply to our work.
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Avoiding Conflicts of Interest
A: No. If your brother’s business is under consideration during the hiring process, you must disclose this conflict to your manager and the Corporate Compliance Department. Bio-Rad may choose to hire this cleaning service, but that decision will have to be made by someone at the company with no family connection to the business.
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A: No. You cannot be involved in hiring or supervising someone with whom you have a close personal relationship. Bio-Rad may hire her for a role, but you need to disclose the relationship to Human Resources.
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A: Maybe, but you have to disclose all outside employment to the Corporate Compliance Department. Even though the job is unrelated to Bio-Rad’s business, it still may affect your ability to perform your role and be a potential conflict.
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A: No, the invitation is considered a gift, which could give the appearance of a conflict of interest.
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A: It can be difficult to determine in some cases, but ask yourself the following questions if you think a situation might create a conflict:
- Would other employees or an outsider think it might affect how I do my job?
- Could it affect any decision I might make at Bio-Rad?
- Do I or my family stand to gain anything from my relationship with the third party doing business with Bio-Rad or vice versa?
- Do I feel under any obligation due to my relationship with the third party doing business with Bio-Rad?
- Would I be embarrassed if anyone inside Bio-Rad knew about the situation?
- How might the situation look to customers or suppliers; would they question whether they had been treated fairly?
If the answer to any of the above questions is “yes” or even “perhaps,” you may have a conflict of interest that you need to disclose.
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A: You return the gift certificate to the customer and immediately notify your manager and the Corporate Compliance Department of the gift.
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A: Inform your line manager about the gift. Where it is impractical to return the gift, it should be shared with others in your work area, or it can be given to a charitable organization.
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Competing Fairly and Following Competition/Antitrust Laws
A: No. You should refuse such an arrangement and immediately end the conversation. If you feel you need market share or other sales data, you should speak with your manager. If anyone ever contacts you with an offer to share sales data or other information, you should decline and contact the Legal Department.
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A: You should not respond but rather contact your manager. He or she can help determine the best way to respond to the statements.
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Complying with Trade Controls and Sanctions
A: No, it is solely Bio-Rad’s responsibility to assign correct HTS for import and export. Please contact the Trade Compliance Department.
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A: Yes, it would be a violation of our export policy and most likely a violation of the law or export regulations. We do not violate export rules under any circumstances; doing so could expose Bio-Rad and its employees to serious civil and criminal sanctions.
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A: Please submit a request to your local master data management (MDM) team to correct the country of origin or contact theTrade Compliance Department
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Gifts and Entertainment
A: No. That entity is a healthcare organization (HCO), and gifts to HCOs are prohibited. The only gifts we can give to an HCO must be of an educational nature and are subject to additional restrictions.
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A: As long as the item in question is of modest value and could not be seen to bias the future selection of the potential vendor, then accepting a small giveaway at a conference is likely okay. Check with the Corporate Compliance Department at [email protected] if you have any questions.
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A: You may visit the facility if there is a legitimate business reason to go and the tour is pre-approved by your manager. In this case, Bio-Rad will pay for travel costs and meals – these costs should not be paid for by the vendor. It is never appropriate to accept tickets to a sporting event from a vendor.
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Interacting with Healthcare Professionals and Healthcare Organizations
A: Yes, payments Bio-Rad makes to HCPs in the U.S. and other jurisdictions must be documented and reported. Contact the Corporate Compliance Department for guidance on how to report these payments.
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A: No. We do not provide entertainment for HCPs in any jurisdiction. Please contact the Corporate Compliance Department for guidance.
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A: No. Bio-Rad promotional materials are developed and reviewed through a rigorous process. You should not alter Bio-Rad’s approved materials or create your own materials.
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Purchasing and Supplier Relations
A: No. When we hear of conduct that would violate our Code, our policies, or the law, we must report it. We want to make sure we work only with those suppliers who adhere to the same legal and ethical standards as Bio-Rad.
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A: Possibly, but you must disclose that you have a relative working for the vendor and make sure there is no conflict of interest and that we are handling the relationship with the vendor in a transparent fashion.
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A: You may accept lunch invitations if you are meeting for a business purpose, but frequent or extravagant meals can appear to create a conflict of interest. Consult your supervisor. Tell the provider about our Code and limit hospitality in a reasonable manner.
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Regulatory and Clinical Standards Compliance
A: Yes. We all must be aware of any regulations that might apply to the work we do at Bio-Rad. If you have any questions at all about what regulations might apply, you should ask your manager.
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A: No. If your role includes research and development activity, you must work with your manager or project team to understand the relevant regulatory or clinical standards, if any, that might apply to your work.
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