Global Business Conduct Standards Policy

Our Mission compels us to contribute to human welfare by researching, designing, manufacturing, and selling products, services, and therapies (collectively, “Medtronic Technology”) that alleviate pain, restore health, and extend life. We recognize that healthcare professionals (“HCPs”) – those best suited to understand the needs of their patients, the performance of Medtronic Technology in the clinical setting, and unmet treatment needs – are critical partners in our ability to fulfill our Mission. We collaborate with HCPs to create new Medtronic Technology and to improve existing Medtronic Technology. We provide world-class training and education to HCPs on the safe and effective use of Medtronic Technology. We sponsor scientific research conducted by HCPs to gather clinical evidence related to Medtronic Technology. All of these interactions are for the ultimate benefit of patients.

Our global Business Conduct Standards regulate interactions between Medtronic employees and any HCPs or healthcare organizations (“HCOs”) who prescribe, purchase, lease, recommend, use, or arrange the purchase or lease of Medtronic Technology.

In no instance will we offer or provide, directly or indirectly, an improper payment or anything of value to HCPs or HCOs as an unlawful inducement to encourage the future purchase or use of Medtronic Technology, or as a reward for prior business.

We define “HCP” to collectively include (i) any individual in a position to recommend or influence the decision to purchase or use Medtronic Technology, such as healthcare providers (e.g., physicians, non-physician practitioners, medical fellows, medical students, and healthcare providers who are government officials), HCO staff members, and HCP relatives; and (ii) any other individuals within scope of government-required transparency reporting. 

We define “HCO” to collectively include (i) any entity in a position to recommend or influence the decision to purchase or use Medtronic Technology, such as institutions engaged in the provision of healthcare (e.g., hospitals, universities, medical practices, home healthcare agencies, and government agencies), companies formed or owned by HCPs to perform personal consulting services (e.g., LLCs), organizations led or directed by HCPs or in which HCPs are members (e.g., patient advocacy groups, medical societies and professional organizations), and any HCO or HCP affiliated organizations; and (ii) any other entities within scope of government-required transparency reporting.

Review the policy written for our employees below: