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Ethical Business

Our approach

At Bristol Myers Squibb, our values and principles guide every decision we make and commit us to the highest standards of ethical behavior. Our compliance program is aligned to the key elements of an effective compliance program as defined by regulatory authorities, including the U.S. Department of Justice, applicable laws and regulations, and industry codes. In fact, our compliance program goes beyond ensuring compliance to building and nurturing a culture of integrity in everything we do.

“The formula of every worthy
business is honor, integrity and
trustworthiness. That is one
formula I cannot change.”

E. R. Squibb, Inventor and Founder
Squibb Company

The Bristol Myers Squibb Principles of Integrity embody our company’s high standards of ethical behavior and form the basis for our interactions with our employees, patients, customers, shareholders and the global community. We have also established distinct Codes of Conduct and Ethics for our Directors, Senior Financial Officers and Third Parties.

In support of the commitment to the highest standard of ethical behavior, the objective for all employees to ‘demonstrate ethics, integrity and quality in everything we do’ is incorporated into BMS’ annual company goals. The key components of this goal are described in the Bristol Myers Squibb Principles of Integrity.

Principles of integrity

At Bristol Myers Squibb, our values and principles guide every decision we make and commit us to the highest standard of moral and ethical behavior. We promise to act on our belief that the priceless ingredient of every product we make is the honor and integrity of its maker. The Principles of Integrity adopted by our Board of Directors set forth the BMS Standards of Business Conduct and Ethics (Principles) on conducting business in a compliant and ethical manner. These Principles embody our high standards of ethical behavior and form the basis for our interactions with our employees, patients, customers, shareholders and the global community. The Principles apply to all BMS employees, including the Board Chair and CEO, the Executive Leadership Team, and the Global Leadership Team, as well as contractors working on behalf of BMS. In addition, the Audit Committee has adopted the Code of Ethics for Senior Financial Officers that supplements the Principles by providing more specific requirements and guidance on certain topics. The Code of Ethics for Senior Financial Officers applies to the Board Chair and CEO, CFO, Controller, Treasurer and the heads of major operating units. Our Board has also adopted the Code of Business Conduct and Ethics for Directors which sets forth guidance to recognize and handle ethical issues.

Our quarterly employee surveys are one of many ways we solicit feedback on and measure our culture of integrity and ethics.

Governance and oversight

Our Chief Compliance and Ethics Officer (CCEO) is part of the company leadership team and reports to the General Counsel, with accountability to the Board Chair and CEO and the Audit Committee of the Board of Directors. The CCEO provides regular updates to the Audit Committee of the Board on the state of the compliance program, including relevant metrics. The CCEO’s reporting structure and private access to the CEO and the Board drive transparent communication and enable the CCEO to act impartially.

Learn more:
Bristol Myers Squibb Principles of Integrity:
Our Standards of Business Conduct and Ethics

Independent assessment

We engage the Ethisphere® Institute to evaluate and benchmark our compliance and ethics program against a database of more than 1,200 companies. Since our first assessment in 2012, we have been awarded their Compliance Leader Verification seal®, indicating a strong and continuously improving compliance program.

The Global Compliance and Ethics department, under the leadership of the CCEO, comprises four global centers of expertise, which support effective implementation of the key elements of our compliance program:

  • Education, Communication, Procedural Documents and Ombudsman
  • Integrity Line and Investigations
  • Global Market Compliance and Compliance Committees
  • Monitoring, Analytics and Third-Party Due Diligence

Country- and regional-level compliance committees are responsible for compliance within their markets. We also have compliance professionals embedded in our regions to provide real-time advice, training and monitoring. The Global Compliance and Ethics Centers of Expertise provide the data analytics, tools and expertise to support our effective monitoring throughout the enterprise.