Building Trust in the Marketplace
Another way we build trust is through our interactions with others in the marketplace. We are committed to acting with integrity and dealing fairly in all our business activities in the marketplace, consistent with the expectations of this Code.
We build trust through ...
We Build Trust with Quality Products
From research and invention, to development, to manufacturing and distribution of our products, we are committed to providing products that are safe and effective. We are also committed to complying with company policies designed to support quality and safety, and all related legal requirements.
Research, development, and product approval
Product manufacturing and quality
Adverse events and product complaints
Product security
We are a company driven by innovation.
Integrity In Action
No, you should never skip any step in a manufacturing process no matter how tight the deadline. Manufacturing process requirements, including those that pertain to safety, should never be compromised. It is important to follow all company processes on which you have been trained and report any deviations. You are also welcome to speak to your manager about options for future process improvement.
We Build Trust Through Responsible Record-Keeping and Reporting
As a publicly traded company, we have a duty to maintain books and records that reflect our financial position and our business transactions accurately and completely. The integrity of our books and records is also essential for successful and effective management of the company.
Accuracy in books and records
As we operate globally, our company books and records must reflect company transactions in a timely manner that is accurate, complete, and understandable. These documents must comply with applicable external legal and accounting requirements as well as Alcon internal policies no matter where the transactions occur.
Requirements for creating and managing documents at Alcon:
- Follow applicable company procedures for making entries and corrections in company books and records. Properly record and submit expense reports that are accurate and timely
- Before approving payments or reimbursements, verify the expenditures appear to be proper. Give approval only for legitimate activities or services that are supported with adequate description or documentation, and verify their consistency with the terms of any related contract, and
- Do not make, request, or facilitate any false, misleading, or artificial entries in Alcon related books or records. Never try to disguise information in records of parties with whom Alcon does business. If you see or suspect that a record related to Alcon business may be false, misleading, or artificial, report it promptly through the speak up process outlined in this Code.
Records retention
You must retain official company records for the time period required by Alcon’s master records retention schedule, and must meet any additional local legal requirements. You must not destroy, alter, delete, or dispose of any documents or records that are requested or required by any government authority or are the subject of any retention instructions from the legal department. Company records retention requirements apply to all Alcon business documents, including electronic communications, whether or not the communications are made and/or stored on an Alcon platform or device.
Public disclosures
We are committed to filing with relevant government authorities, on a timely basis, reports that are accurate, complete, and compliant with applicable regulations. This includes, by way of example, periodic earnings filings made with regulatory authorities and transparency reporting. If you are involved in making these disclosures, you must follow all applicable legal and company requirements.
Integrity In Action
You should report the situation promptly to the company as outlined in the “speak up” section of this Code. If the customer does return the products, both the customer and sales personnel may have received unjust financial benefits in the form of volume-based sales rebates or commissions, which could be considered fraudulent. This would also result in a misstatement of revenue and receivables in Alcon financial statements filed with securities authorities, which if material, could lead to government fines or penalties for Alcon.
We Build Trust Through Ethical Interactions
We are committed to conducting all our interactions responsibly and with integrity.
We are committed to conducting our customer interactions and other professional practices responsibly and with integrity. Because we work in a highly regulated industry, it is important for you to keep in mind certain core principles to guide your actions in the marketplace. Before acting, ask yourself these questions:
- Are you putting patients and consumers first?
- Are you acting with clear and proper purpose?
- Are you engaging appropriately?
- Are you researching for the right reason?
- Are you funding and donating responsibly?
In addition, you must follow legal and industry code requirements and company policies that apply to our customer interactions and other professional practices.
We are committed to competing vigorously in the marketplace in a fair and compliant manner, and to earning our business success on the merits of our products and services, excellent customer service, and competitive prices. This means we:
- Present our products, services, and sales programs in a clear, honest, and forthright manner
- Do not engage in or tolerate unfair methods of competition, including unfair or deceptive practices
- Do not misrepresent information about ourselves, Alcon, or our Alcon affiliation, and
- Do not engage in coordinated practices that reflect deliberate, intentional collaboration between Alcon and other companies for the purpose of eliminating or restricting competition in a certain market or markets.
We hold our suppliers, distributors, and third parties who are contracted to act on behalf of Alcon to the same standards of integrity to which we hold ourselves. We expect our suppliers and business partners to uphold the commitments stated in the Alcon Third Party Code of Conduct.
Before contracting with a third party, you are expected to:
- Base your selection on the merit, quality of goods or services, and/or professional skills and reputation of the third party
- Follow applicable company third party screening processes, and
- Verify that appropriate provisions are included in the contract to reflect the third party’s obligation to comply with the law and relevant Alcon policies.
In the case of suppliers, you must also:
- Act in the best interests of Alcon, not allowing any gifts or other personal or family interests to influence your business decisions made on behalf of Alcon, and
- Not attempt to exert inappropriate influence on any employee of an existing or potential supplier.
In the course of conducting Alcon business, you may interact with regional, national, provincial, state, county, or local government employees or officials. In countries that have a nationalized or public healthcare system, healthcare professionals may be considered government officials.
We expect you to:
- Initiate contact with government employees or officials on behalf of Alcon only if this is part of your assigned job responsibilities
- Refer inquiries from government employees or officials to the appropriate company contact for response
- Cooperate respectfully with government authorities who regulate our products and business activities
- When submitting Alcon information to government entities or representatives, submit only information that is accurate, complete, and not misleading
- Do nothing that could be regarded as giving or offering an inappropriate inducement or reward for doing business with Alcon or taking a particular action that benefits Alcon, and
- Comply with all applicable ethical standards and legal limitations that apply to interactions with government and public officials (for example, restrictions on offering or providing gifts, meals, travel, entertainment, services, payment, or items of value to government employees, contractors, and agents.)
It is your responsibility to consult with your local compliance officer or a company lawyer to determine what law and restrictions apply.
Our external communications about Alcon business matters can impact the trust we have built in our company brand and reputation. It is important for us to communicate accurately, clearly, and consistently when we provide information. Only certain associates are authorized to speak externally on our behalf with various audiences, for example, the news media or investors.
You must not communicate externally on behalf of Alcon if it is not part of your job responsibilities. You should refer any external inquiries you receive to the appropriate company contact.
While we support the use of social media, you must use it responsibly and in accordance with company policies when discussing Alcon related topics, products, and services. Be mindful that posting on any social media platform can result in unintended consequences for both you and Alcon.
Integrity In Action
You should not respond to any information published or posted publicly unless you are an authorized company spokesperson. It is important, however, to inform Corporate Affairs at [email protected], so that appropriate follow up action may be considered.
We Build Trust Through Ethical Transactions
Anti-bribery
We do not tolerate bribery, or anything that could be perceived as bribery, in any form. Bribery can damage trust and is inconsistent with our commitment to integrity and respect for our stakeholders.
You must not offer, promise, approve, or provide anything of value (for example, a payment, gift, meal, travel, entertainment, loan, service, or donation) improperly to induce or reward business decisions related to Alcon products or services. You may offer and provide business courtesies such as modest meals and nominal items only if they comply with applicable company policies as well as legal requirements, industry codes, and ethical standards that pertain to the proposed recipient. You must also follow Alcon third-party screening processes when required by company procedures.
Securities trading
From time to time while doing your job, you may learn of certain confidential information regarding Alcon or another company. If this information could have a positive or negative impact on the price of Alcon’s or the other company’s securities, including stocks and bonds, it is considered material, non-public information.
It is unethical and illegal to buy, sell, trade, or donate securities of any company about which you have knowledge of material non-public information, or to tip others who might make an investment decision based on this information. Follow all company policies that apply when trading in securities.
International Trade Restrictions
We are a global company that engages in international trade every day. If you are involved in international trade transactions, or carry any Alcon products internationally for business purposes, you must meet all applicable laws and company requirements, including detailed trade compliance policies that apply to the following topics:
- Import and Export Controls – All Alcon exports (both tangible and intangible) and imports must be properly classified and valued and must meet all applicable import and export requirements and restrictions.
- Requirements can vary under local laws and apply both to transfers between Alcon affiliates as well as to transfers between Alcon and external parties.
- If you plan to hand-carry commercial goods, professional equipment, or other Alcon-related goods while traveling, you may only do so in a manner permitted by law. Obtain advice and prior approval from the Export and Sanctions Trade Compliance staff ([email protected]) and the destination affiliate’s Trade Compliance Manager.
- Boycotts – You must meet company reporting and approval requirements before acting on a request or inquiry relating to a boycott of a country. This is true even if Alcon will not respond to or comply with the boycott request. Direct questions to Alcon’s Global Trade Compliance staff ([email protected]).
- Trade Sanctions – Various governments impose trade restrictions on countries, territories, entities, and individuals. You must verify that transactions are permissible before engaging in or committing to conduct company business with entities or individuals that you know or have reason to believe may be sanctioned, restricted, or debarred by a government. This is true for all types of Alcon transactions (e.g., research, manufacturing, purchases from suppliers, sales of company products, grants or donations, business travel, financial transactions, etc.) All activities and transactions involving sanctioned territories or parties must have prior written approval from Alcon’s Global Trade Compliance staff ([email protected]). You must also follow relevant third-party screening procedures when applicable.
Integrity In Action
If this information is not already publicly known, it is not okay to respond to your friend’s question. If you are not sure if it is public, check with a company lawyer.
We must always follow import and export legal requirements because breaking these laws could expose us to serious risk, including possible fines and penalties. Check with Global Trade Compliance staff to determine the most efficient way to handle this situation.