provide money or its equivalent, gifts, meals or entertainment of any value to any government employee, unless specifically allowed by law. Laws concerning this matter are often complex and vary from country to country. Before offering or accepting any gifts, meals or entertainment to or from a government official, consult with the Global Law department or your local Compliance Officer.

Bribery and Corruption

Often in our industry, a country's government is both the regulator of our products and a major customer. We also retain the services of scientists and doctors for consulting and research activities and many of them are employees of public institutions and may be considered government employees.

Most countries in which we do business have laws that forbid making, offering or promising any payment or giving anything of value (directly or indirectly) to a government employee when the payment or gift is intended to influence an official act or decision to obtain or retain business or secure an unfair business advantage. Under the U.S. Foreign Corrupt Practices Act, foreign political parties and candidates as well as officers and employees of state-owned companies are considered