A Promise to Transform Lives

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 employees and representatives, 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 and representatives are also encouraged to raise questions pertaining to business integrity, including conduct of a St. Jude Medical employee or anyone else representing the company. Issues should be raised by all St. Jude Medical personnel, regardless of whether they are employees and no matter their job 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.


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.