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Fair Business Practices

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Focusing on Fair Business Practices

We believe in conducting business in a fair and transparent manner and are committed to conducting our business ethically. We will only engage in fair and open competition in compliance with applicable laws, rules and regulations.

We do not engage in, or tolerate engagement in, any form of corrupt practices or fraudulent activities, including any anti-competitive practices such as price-fixing, collusion or entering into illegal or anti-competitive agreements to win or retain business. We respect the Intellectual PropertyIntellectual Property means all intellectual property rights of any kind, including all patents, trademarks, service marks, logos, domain names, trade names, copyrights, trade secrets, know-how; inventions, discoveries, ideas, databases, plans, lists and similar rights; and all registrations of, applications for, and other rights with respect to any of the above. rights of others and do not illegally or unethically obtain proprietary information about our competitors or their products.

We believe in conducting business in a fair and transparent manner and are committed to conducting our business ethically. We will only engage in fair and open competition in compliance with applicable laws, rules and regulations.

We do not engage in, or tolerate engagement in, any form of corrupt practices or fraudulent activities, including any anti-competitive practices such as price-fixing, collusion or entering into illegal or anti-competitive agreements to win or retain business. We respect the Intellectual PropertyIntellectual Property means all intellectual property rights of any kind, including all patents, trademarks, service marks, logos, domain names, trade names, copyrights, trade secrets, know-how; inventions, discoveries, ideas, databases, plans, lists and similar rights; and all registrations of, applications for, and other rights with respect to any of the above. rights of others and do not illegally or unethically obtain proprietary information about our competitors or their products.

Antitrust and Fair Competition

Antitrust and fair competition laws are designed to promote and protect competition in the marketplace. We believe that fair competition fosters innovation and benefits our customers and patients by bringing a wide range of products to the market and balanced pricing for these products.

We do not tolerate any verbal or written agreements with suppliers, wholesalers, distributors, customers, competitors or any third party that may illegally limit the free market. No agreement or understanding may be made with competitors to directly or indirectly control prices, including any element of pricing such as discounts, rebates or cost. We will not allocate products, markets or territories to boycott certain customers or suppliers, unless required to by trade law.

Antitrust and fair competition laws are designed to promote and protect competition in the marketplace. We believe that fair competition fosters innovation and benefits our customers and patients by bringing a wide range of products to the market and balanced pricing for these products.

We do not tolerate any verbal or written agreements with suppliers, wholesalers, distributors, customers, competitors or any third party that may illegally limit the free market. No agreement or understanding may be made with competitors to directly or indirectly control prices, including any element of pricing such as discounts, rebates or cost. We will not allocate products, markets or territories to boycott certain customers or suppliers, unless required to by trade law.

Examples of Potential Antitrust Concerns

Examples of Potential Antitrust Concerns

  • Prohibiting distributors from reselling a product below a specified price.
  • Disclosing pricing information to competitors that is not publicly available.
  • Working with a competitor on customer bids.

Examples of Potential Antitrust Concerns

  • Prohibiting distributors from reselling a product below a specified price.
  • Disclosing pricing information to competitors that is not publicly available.
  • Working with a competitor on customer bids.

If you suspect a violation of antitrust or fair competition laws has occurred, promptly contact your manager, local Ethics and Compliance Department, the Legal Department or the Business Ethics Hotline. Seek guidance when considering projects that have the potential to violate antitrust or fair competition laws.

If you suspect a violation of antitrust or fair competition laws has occurred, promptly contact your manager, local Ethics and Compliance Department, the Legal Department or the Business Ethics Hotline. Seek guidance when considering projects that have the potential to violate antitrust or fair competition laws.

Our Expectations

  • We will not agree to divide up customers or territories with competitors.
  • We will not discuss, propose or enter verbally or in writing into any agreements that may violate antitrust or fair competition laws or inappropriately align pricing, bidding or tender strategies.
  • We are careful during trade association meetings or business events not to discuss or exchange, directly or through a third party, sensitive competitive information.

Please see International Trade Controls Compliance Policy For Bausch + Lomb Colleagues Only for further information.

  • We will not agree to divide up customers or territories with competitors.
  • We will not discuss, propose or enter verbally or in writing into any agreements that may violate antitrust or fair competition laws or inappropriately align pricing, bidding or tender strategies.
  • We are careful during trade association meetings or business events not to discuss or exchange, directly or through a third party, sensitive competitive information.

Please see International Trade Controls Compliance Policy For Bausch + Lomb Colleagues Only for further information.

Ethical Communications

We are committed to being a valued and trusted health care partner. We support clinical study data transparency to serve participants, researchers and health care providers, and to advance scientific knowledge and improve patient care. When providing access to clinical trial information, we consider the importance of protecting patient privacy and maintaining incentives for future innovative data generation and research.

We are committed to being a valued and trusted health care partner. We support clinical study data transparency to serve participants, researchers and health care providers, and to advance scientific knowledge and improve patient care. When providing access to clinical trial information, we consider the importance of protecting patient privacy and maintaining incentives for future innovative data generation and research.

We provide medically relevant, clinically accurate and comprehensive product information to enable well-informed treatment decisions and risk-benefit assessments about our products. We communicate with Health Care ProfessionalsHealth Care Professional (“HCP”) includes licensed medical practitioners, medical staff members involved in providing patient care, including, but not limited to, physicians, nurses, nurse practitioners, physician assistants, medical assistants, office technicians, dentists, dental assistants, dental hygienists, medical residents, pharmacists, optometrists, opticians and other individuals in the position to arrange for or recommend Bausch + Lomb products. (“HCP”) and customers in many ways.

We provide medically relevant, clinically accurate and comprehensive product information to enable well-informed treatment decisions and risk-benefit assessments about our products. We communicate with Health Care ProfessionalsHealth Care Professional (“HCP”) includes licensed medical practitioners, medical staff members involved in providing patient care, including, but not limited to, physicians, nurses, nurse practitioners, physician assistants, medical assistants, office technicians, dentists, dental assistants, dental hygienists, medical residents, pharmacists, optometrists, opticians and other individuals in the position to arrange for or recommend Bausch + Lomb products. (“HCP”) and customers in many ways.

Our Expectations

  • We are truthful, accurate, balanced and free from false, misleading or exaggerated claims in our marketing practices and scientific communications.
  • We do not make false comments about a competitor or their products or make false or misleading advertising claims.
  • We promote our products in a manner consistent with a product’s approved indication or use and labeling.
  • We are committed to business communications that reflect integrity and are consistent with applicable laws.
  • We are truthful, accurate, balanced and free from false, misleading or exaggerated claims in our marketing practices and scientific communications.
  • We do not make false comments about a competitor or their products or make false or misleading advertising claims.
  • We promote our products in a manner consistent with a product’s approved indication or use and labeling.
  • We are committed to business communications that reflect integrity and are consistent with applicable laws.

Anti-Bribery

In every territory where we operate, our practices are consistent with international anti-corruption laws. We are committed to complying with the letter and spirit of the U.S. Foreign Corrupt Practices Act (“FCPA”), the Canadian Corruption of Foreign Public Officials Act, the United Kingdom Bribery Act and all other laws and regulations relating to the bribery or corruption of Government OfficialsGovernment Official is any officer or colleague of a government, or any department, agency or entity. in all jurisdictions where we operate.

In every territory where we operate, our practices are consistent with international anti-corruption laws. We are committed to complying with the letter and spirit of the U.S. Foreign Corrupt Practices Act (“FCPA”), the Canadian Corruption of Foreign Public Officials Act, the United Kingdom Bribery Act and all other laws and regulations relating to the bribery or corruption of Government OfficialsGovernment Official is any officer or colleague of a government, or any department, agency or entity. in all jurisdictions where we operate.

As a guiding principle, we may not promise, offer, pay or accept anything of value, either directly or indirectly via suppliers, distributors, consultants, lawyers, agents or any other third party to improperly obtain or retain business, influence business or government decisions or secure an unfair business advantage.

We strictly prohibit the payment of bribes, directly or indirectly, and all improper payments or favors, including to all Government OfficialsGovernment Official is any officer or colleague of a government, or any department, agency or entity., HCPsHealth Care Professional (“HCP”) includes licensed medical practitioners, medical staff members involved in providing patient care, including, but not limited to, physicians, nurses, nurse practitioners, physician assistants, medical assistants, office technicians, dentists, dental assistants, dental hygienists, medical residents, pharmacists, optometrists, opticians and other individuals in the position to arrange for or recommend Bausch + Lomb products., suppliers, distributors, other third parties acting on our behalf and our customers anywhere in the world. Government Officials can include HCPs working in, or paid for by, a government health care facility or institution, system university or hospital.

Paying for meals, entertainment or travel expenses for government officials or HCPs may be viewed as an improper influence. Laws and regulations regarding paying for these types of expenses for HCPs vary from country to country. Please check corporate and local policies for further direction. When in doubt, seek guidance from the Ethics and Compliance or Legal Departments.

As a guiding principle, we may not promise, offer, pay or accept anything of value, either directly or indirectly via suppliers, distributors, consultants, lawyers, agents or any other third party to improperly obtain or retain business, influence business or government decisions or secure an unfair business advantage.

We strictly prohibit the payment of bribes, directly or indirectly, and all improper payments or favors, including to all Government OfficialsGovernment Official is any officer or colleague of a government, or any department, agency or entity., HCPsHealth Care Professional (“HCP”) includes licensed medical practitioners, medical staff members involved in providing patient care, including, but not limited to, physicians, nurses, nurse practitioners, physician assistants, medical assistants, office technicians, dentists, dental assistants, dental hygienists, medical residents, pharmacists, optometrists, opticians and other individuals in the position to arrange for or recommend Bausch + Lomb products., suppliers, distributors, other third parties acting on our behalf and our customers anywhere in the world. Government Officials can include HCPs working in, or paid for by, a government health care facility or institution, system university or hospital.

Paying for meals, entertainment or travel expenses for government officials or HCPs may be viewed as an improper influence. Laws and regulations regarding paying for these types of expenses for HCPs vary from country to country. Please check corporate and local policies for further direction. When in doubt, seek guidance from the Ethics and Compliance or Legal Departments.

Our Expectations

  • We make legitimate arms-length business purchases of goods and services at fair market value.
  • We only provide grants or donations to a government entity or customer when permitted locally and when there is no expectation of receiving anything of value in return.
  • We do not make payments to Government Officials Government Official is any officer or colleague of a government, or any department, agency or entity. to secure any advantage, including to expedite government functions.

Please see the Global Anti-Bribery Policy for further information.

  • We make legitimate arms-length business purchases of goods and services at fair market value.
  • We only provide grants or donations to a government entity or customer when permitted locally and when there is no expectation of receiving anything of value in return.
  • We do not make payments to Government Officials Government Official is any officer or colleague of a government, or any department, agency or entity. to secure any advantage, including to expedite government functions.

Please see the Global Anti-Bribery Policy for further information.

Integrity of Business Records and Reporting

We will record and report all data and information accurately, honestly and in appropriate detail. This applies both to everyday documents such as recording financial transactions, expense reports, test reports, manufacturing records and accounting entries, as well as to other less routine documents or reports, and are accurately reported to external and internal stakeholders.

We will record and report all data and information accurately, honestly and in appropriate detail. This applies both to everyday documents such as recording financial transactions, expense reports, test reports, manufacturing records and accounting entries, as well as to other less routine documents or reports, and are accurately reported to external and internal stakeholders.

Our Expectations

  • We support global efforts to fight corruption.
  • Our books, records and documents accurately reflect and properly describe the transactions in appropriate detail.
  • We ensure our financial records are accurate.
  • We only enter compliant business transactions.
  • We do not create undisclosed or unrecorded funds, assets or accounts for any purpose.
  • We make truthful and accurate entries in our books and records.
  • We classify and allocate costs in accordance with applicable accounting rules and regulations.
  • We support global efforts to fight corruption.
  • Our books, records and documents accurately reflect and properly describe the transactions in appropriate detail.
  • We ensure our financial records are accurate.
  • We only enter compliant business transactions.
  • We do not create undisclosed or unrecorded funds, assets or accounts for any purpose.
  • We make truthful and accurate entries in our books and records.
  • We classify and allocate costs in accordance with applicable accounting rules and regulations.

Gifts and Entertainment

The provision of gifts, entertainment and other types of favors, directly or indirectly, to any HCP or government official with the intent to influence their decision-making ability is prohibited. As a global company with diverse products and services, we also conduct business with customers and their representatives who are not HCPsHealth Care Professional (“HCP”) includes licensed medical practitioners, medical staff members involved in providing patient care, including, but not limited to, physicians, nurses, nurse practitioners, physician assistants, medical assistants, office technicians, dentists, dental assistants, dental hygienists, medical residents, pharmacists, optometrists, opticians and other individuals in the position to arrange for or recommend Bausch + Lomb products. or Government OfficialsGovernment Official is any officer or colleague of a government, or any department, agency or entity.. While bribery is always prohibited, there are times when a non-HCP or non-governmental customer may receive a lawful modest gift and reasonable entertainment.

The provision of gifts, entertainment and other types of favors, directly or indirectly, to any HCP or government official with the intent to influence their decision-making ability is prohibited. As a global company with diverse products and services, we also conduct business with customers and their representatives who are not HCPsHealth Care Professional (“HCP”) includes licensed medical practitioners, medical staff members involved in providing patient care, including, but not limited to, physicians, nurses, nurse practitioners, physician assistants, medical assistants, office technicians, dentists, dental assistants, dental hygienists, medical residents, pharmacists, optometrists, opticians and other individuals in the position to arrange for or recommend Bausch + Lomb products. or Government OfficialsGovernment Official is any officer or colleague of a government, or any department, agency or entity.. While bribery is always prohibited, there are times when a non-HCP or non-governmental customer may receive a lawful modest gift and reasonable entertainment.

Our Expectations

  • We will not bribe or give the appearance of bribing any third parties, including customers, HCPsHealth Care Professional (“HCP”) includes licensed medical practitioners, medical staff members involved in providing patient care, including, but not limited to, physicians, nurses, nurse practitioners, physician assistants, medical assistants, office technicians, dentists, dental assistants, dental hygienists, medical residents, pharmacists, optometrists, opticians and other individuals in the position to arrange for or recommend Bausch + Lomb products.,

    Government OfficialsGovernment Official is any officer or colleague of a government, or any department, agency or entity.

    or vendors.
  • We provide moderate and appropriate business meals for customers.
  • We follow local laws on appropriate entertainment, moderate gifts or favors for non-governmental and non-HCP customers.
  • We abide by the policies and rules of our customers’ employers regarding modest gifts, entertainment, meals or other benefits.

For more information, please see our Global Anti-Bribery Policy.

  • We will not bribe or give the appearance of bribing any third parties, including customers, HCPsHealth Care Professional (“HCP”) includes licensed medical practitioners, medical staff members involved in providing patient care, including, but not limited to, physicians, nurses, nurse practitioners, physician assistants, medical assistants, office technicians, dentists, dental assistants, dental hygienists, medical residents, pharmacists, optometrists, opticians and other individuals in the position to arrange for or recommend Bausch + Lomb products.,

    Government OfficialsGovernment Official is any officer or colleague of a government, or any department, agency or entity.

    or vendors.
  • We provide moderate and appropriate business meals for customers.
  • We follow local laws on appropriate entertainment, moderate gifts or favors for non-governmental and non-HCP customers.
  • We abide by the policies and rules of our customers’ employers regarding modest gifts, entertainment, meals or other benefits.

For more information, please see our Global Anti-Bribery Policy.

Third Party Management

We engage third parties to assist in various areas of our business, including research and development, sales, marketing, supply chain and manufacturing. We actively avoid any conflicts of interest with third parties, whether real or perceived. When a third party conducts business on our behalf, we are accountable for their actions. We ensure they operate at the same level of transparency and integrity as we expect of ourselves.

We engage third parties to assist in various areas of our business, including research and development, sales, marketing, supply chain and manufacturing. We actively avoid any conflicts of interest with third parties, whether real or perceived. When a third party conducts business on our behalf, we are accountable for their actions. We ensure they operate at the same level of transparency and integrity as we expect of ourselves.

Our Expectations

  • We conduct appropriate due diligence on our third parties to ensure we are engaging only with reputable partners.
  • We expect third parties that act on our behalf to follow our Code or to follow their own codes if they are equivalent.
  • We treat our third parties with respect and expect the same in return.

Please see Procurement and Sourcing Policy for further information.

  • We conduct appropriate due diligence on our third parties to ensure we are engaging only with reputable partners.
  • We expect third parties that act on our behalf to follow our Code or to follow their own codes if they are equivalent.
  • We treat our third parties with respect and expect the same in return.

Please see Procurement and Sourcing Policy for further information.

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