Gifts and Entertainment

Any gifts and entertainment given or received must be modestly valued, exchanged infrequently, appropriate, and tied to a legitimate business purpose.

We succeed at Bio-Rad through innovation and providing for our customers’ needs. We do not seek to gain a business advantage or improperly influence anyone by providing improper or lavish gifts or entertainment, and we recognize that we may only provide or receive modest, infrequent, and appropriate gifts and entertainment that are related to a legitimate business purpose.

We never provide gifts or entertainment of any kind to government officials.

On occasion, we may offer to pay travel expenses for a business partner to demonstrate products and services or in connection with performance of an agreement, as long as such expenses are reasonable and consistent with our internal travel policies.

We do not solicit or accept gifts, gratuities, kickbacks, or payments for ourselves or our family members that could be seen as an attempt to influence our decision-making at Bio-Rad. We do not accept gratuities, kickbacks, improper payments, or lavish or inappropriate gifts or from anyone we do business with, including customers, suppliers, and consultants.

    • Cash and cash equivalents (such as gift cards)
    • Tickets to sporting events or concerts
    • Contributions to political events, parties, or candidates
    • Unapproved contributions to charitable events or organizations (hewing closer to original code – we can’t flatly outlaw contributions to all charitable events.)
    • Any sort of kickback
      • Offered infrequently
      • Modest in value
      • Related to legitimate business discussions
      • Shared only with our customers and business partners, not their family members or friends
      • Pre-approved by the Corporate Compliance Department via the online system
        • Are related to legitimate business discussions
        • Are modest in value
        • Could not be seen to influence our decision-making in any way
        • Are pre-approved by the Corporate Compliance Department via the online system
          • Pay for our participation
          • Receive prior permission from our supervisor
            • Politely refuse and report it to our supervisor
            • Return it to the giver if it cannot be refused
            • Give it to our supervisor if it cannot be returned

            Expectations


            • We never provide gifts or entertainment to government officials.
            • We obtain prior approval from the Corporate Compliance Department using our online system before giving or receiving any gifts or entertainment.
            • We neither give nor accept gifts or entertainment that could appear to improperly influence either party’s business decision-making.

            Training Videos in Multiple Languages

            Key Terms

              Gifts include any item (branded or unbranded) that is capable of use by or of value to a third party (or his or her family members, office staff, or friends) for non-educational purposes, even if the item is of minimal value and related to the third party’s work or is for the benefit of patients.

                Our software platform designed to track the submission and approval of transactions involving payment or other transfers of value by Bio-Rad to customers, potential customers, Government Officials (GOs), Government Entities (GEs), Healthcare Professionals (HCPs) and Healthcare Organizations (HCOs).

                  Members of the healthcare community, including but not limited to Healthcare Professionals (HCPs) and Healthcare Organizations (HCOs), and other individuals or entities to whom Bio-Rad promotes or sells or could promote or sell products, including but not limited to wholesalers, distributors, pharmacies, and PhDs.

                    Compensation to an individual for making a business decision favorable to the payor.

                    FAQs

                    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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