Governance

Boston Scientific seeks to act ethically in our business practices, comply with local tax and business laws and regulations, and be transparent in our reporting.  We extend these practices to our operations as well as to our customers, suppliers and communities in which we operate.

Boston Scientific seeks to comply with all local country laws including country tax laws, to promote transparency and conduct tax reporting as required under applicable rules and regulations; Boston Scientific includes disclosure regarding tax matters in its annual report on Form 10-K filed with the US Security and Exchange Commission.

The business and affairs of Boston Scientific are managed by or under the direction of its Board of Directors.  The Board of Directors of Boston Scientific, including through one or more of its committees, reviews Boston Scientific’s tax structure and strategies on a regular basis.

Boston Scientific is committed to acting ethically in dealing with customers, employees, shareholders, partners, suppliers, competitors, and the community and with respect for applicable laws. One way that we make this happen is through the implementation of our Global Compliance Program, and our Code of Conduct, both of which are discussed in more detail in the Compliance and Ethics portion of our internet site. The primary purpose of our compliance program is to detect and prevent violations of laws, regulations, and company policies, taking into account and tailoring the program to our unique environment.

As part of Boston Scientific’s commitment to acting ethically in all matters and with respect for all applicable laws, due diligence is conducted of new channel business partners, during which time Boston Scientific looks to partner with other entities that demonstrate a similar commitment to acting ethically in these matters.

The Corporate Citizenship section of Boston Scientific’s company website clearly communicates the company’s commitment to acting ethically in all dealings.  This website reflects the information communicated to our employees through formal training and knowledge-based testing, as well as via direct email.

Employees are required annually to complete a training course on ethics and compliance, including a section on anti-corruption.

As part of our standard audit process, operational risks are assessed, including those at risk of corruption.

Our Code of Conduct is about acting with integrity by treating people honestly and with respect, both inside and outside of Boston Scientific.  This Code lays out clear guidelines for dealing with corruption, as well as various means to ask a question or confidentially raise a concern should a related issue arise.

Boston Scientific maintains policies and procedures reasonably designed to comply with compliance and anti-corruption rules and regulations.  Violations of such policies may lead, and has led, to discipline up to and including termination.