Leading Today, Respecting Tomorrow

Ethical Business Conduct

Code of Business Conduct

We believe that ethical business behavior is paramount to a business’s success, integrity and sustainability. The St. Jude Medical Code of Business Conduct not only serves as the framework for upholding responsible actions and beliefs, but also helps demonstrate our commitment to complying with applicable laws and regulations.

The Code of Business Conduct applies globally to all St. Jude Medical business units and subsidiaries, and has been translated into several languages. In addition to conducting our business with integrity, we are committed to complying with laws around the world that apply to our business.

St. Jude Medical gives each new employee a copy of its Code of Business Conduct. The company continues to foster awareness by posting its Code of Business Conduct on our web and intranet sites and by redistributing electronic versions to our employees annually. St. Jude Medical has made a concerted effort to promote the Code of Business Conduct internally, including electronic training on relevant topics and cross-referencing in other policies and procedures. All St. Jude Medical employees are expected to be familiar with and adhere to the Code.

Our Code of Business Conduct obligates each employee to do the right thing and report an actual or apparent violation of the law or company policy. Employees are also encouraged to raise questions pertaining to business integrity, whether about a St. Jude Medical employee or anyone else representing the company. Issues should be raised by any employee — no matter his or her rank or location. The company strictly prohibits retaliation against anyone who, in good faith, reports possible misconduct, asks a legitimate question or cooperates in an investigation.

In addition to support from in-person resources such as department managers, supervisors or legal and human resource representatives, St. Jude Medical has established a Business Integrity HelpCenter. The HelpCenter includes telephone and online options for reporting potential misconduct or asking questions and is available 24 hours a day, with access to translators who can collectively communicate in over 150 languages. The Business Integrity HelpCenter is also available to contractors, distributors, independent sales representatives and other external stakeholders.

To view the St. Jude Medical Code of Business Conduct or find contact information for the St. Jude Medical Business Integrity HelpCenter, visit sjm.com/business-integrity.

AdvaMed

St. Jude Medical is a member of the Advanced Medical Technology Association (AdvaMed), the world’s largest medical technology association. AdvaMed advocates for a legal, regulatory and economic climate that advances global health care by assuring that patients have access to the benefits of medical technology. In the U.S., St. Jude Medical supports the AdvaMed Code of Ethics. Outside the U.S., the company supports numerous industry codes of ethics, including Eucomed in Europe. As a supporter of the AdvaMed Code of Ethics, St. Jude Medical is certified to follow the AdvaMed Code of Ethics on Interactions with Health Care Professionals to ensure a high standard of ethical conduct.

Physician Payment Sunshine Act

St. Jude Medical supports the transparency goals of the Physician Payment Sunshine Act, which is part of the federal health care reform bill passed in 2010. Its aim is to provide public access to monetary and in-kind exchanges between medical technology companies, and U.S. physicians and U.S. teaching hospitals. While collaboration and interactions between medical technology companies and health care professionals are essential to advancing new, safe and effective medical technologies that benefit patients, St. Jude Medical recognizes and agrees that health care professionals must make independent decisions regarding the health care of their patients, and that we need to provide patients with enhanced transparency into relationships between manufacturers and our customers. The Sunshine Act was enacted to provide that transparency. St. Jude Medical has business systems in place to support the Sunshine Act, and began capturing the required data on August 1, 2013. We will begin to publish this information in accordance with the Physician Payment Sunshine Act requirements in September 2014.