At Thermo Fisher Scientific, everything we do begins with our Mission - to enable our customers to make the world healthier, cleaner, and safer. Our company’s core values, which include acting with Integrity and demonstrating the highest ethical standards, play an important role in helping us achieve that Mission.
We are committed to conducting our business ethically and in compliance with the laws of the countries where we operate. As a member of the United Nations (UN) Global Compact since 2019, Thermo Fisher Scientific is working to implement the Ten principles as part of our strategy, culture, and operations.
Therefore it is the policy of Thermo Fisher Scientific to (i) require the highest standards of business ethics and integrity on the part of all employees and (ii) to comply with all applicable laws and regulations in the conduct of our business. To that end, Thermo Fisher Scientific has adopted and implemented a Code of Business Conduct and Ethics (the “Code”). All directors, officers, and employees of the Company are responsible for reviewing this Code and certifying annually that he or she has reviewed and is in compliance with the Code. In addition, all employees are given annual training on specific Code elements to ensure they have a complete understanding of what is expected of them. The Code covers a very broad range of topics, including, but not limited to, policies related to conflicts of interest, gift-giving, honest and ethical fair dealing, insider trading, export control awareness, health and safety, privacy matters, sexual harassment, etc.
Our Code of Conduct is supplemented by position statements on individually identified business ethics issues.
Thermo Fisher’s sales and marketing activities are guided by clear principles that underscore our commitment to operating ethically:
The purpose of our ethics and compliance program is to prevent and detect violations of law or company policy. Everyone must do their part to honor our 4i Values and maintain our high ethical standards. Colleagues are encouraged to report any issues to their manager, Human Resources or Legal departments or via our Global Ethics Hotline, which is a confidential incident reporting system available to all our stakeholders including customers, suppliers and other external parties.
We are committed to upholding and respecting human rights for all. Building a brighter future means managing our global operations ethically and with integrity to positively impact the people and communities linked to our business.
Thermo Fisher is able to support human rights for all people by conducting business with the highest ethical standards and in compliance with applicable laws and Company policy. We are guided by principles set forth in our Human Rights and Equal Opportunity Policy, which was updated in 2022 and establishes our standards for business conduct related to respecting human rights and fair labor practices across our global operation.
This policy helps us implement our commitment to human rights in alignment with leading international standards, including the UN Universal Declaration of Human Rights and the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work. As signatories to the UN Global Compact, we are also committed to aligning our corporate strategy with the Ten Principles on human rights, labor, environment and anti-corruption. When differences arise between our standards and legal requirements, we generally apply the stricter standard in compliance with
Through our human rights management approach, we engage transparently and collaboratively with our stakeholders to drive the effectiveness of our program.
Colleagues: Our Code of Business Conduct and Ethics outlines the expectations for all directors, officers and colleagues of the Company, including compliance with all internal policies such as those governing human rights. Annual certification of compliance with this code is required and biannual training enhances our colleagues knowledge of human rights within the context of our business and their role in respecting them. Our procurement colleagues receive additional training on the expectations of our supplier responsibility programs, including those related to labor and human rights for our suppliers.
Suppliers: Our Supplier Code of Conduct shares our compliance expectations for suppliers and their subcontractors in the areas of ethics, labor, health and safety, environment, and management systems. It is integrated into supply agreements and terms and conditions, and suppliers are expected to share their performance against code expectations at the request of Thermo Fisher. Suppliers must have a training program to educate their workforce to address the expectations outlined in this code and are required to participate in Thermo Fisher trainings, as applicable.
Customers and distribution partners: We provide training, education and resources to help customers, resellers and distributors use our instruments and products as designed and to follow global scientific and ethical standards for the responsible selling, or reselling, of our technologies. Should we be alerted to any ethical question or concern in relation to how customers may be using our technologies, the matter is immediately escalated to our Bioethics Committee.
Policymakers and influencers: We engage with governments, regulators and non-governmental organizations to contribute to good global policy, such as the responsible application of technology and appropriate security protocols and procedures for safeguarding individual privacy rights.
Active engagement and feedback from our partners support the continuous improvement of our approach. If, at any time, a stakeholder has a human rights concern, they have the option to contact our Global Ethics Hotline and can submit a report anonymously if desired.
As the world leader in serving science, Thermo Fisher Scientific has a single Mission: to enable our customers to make the world healthier, cleaner, and safer. To fulfill our Mission, we aspire to hold a clear leadership position for life sciences, healthcare, the environment, and public safety.
As science continues to evolve at an unprecedented pace, it is important that we ethically pursue and uphold our promise to serve as a responsible steward to benefit society. We believe biotechnology not only offers meaningful advancements for science but also bears important responsibilities to companies like ours who develop and employ these tools.
We place the utmost importance on identifying, understanding, assessing, tracking, managing, and overseeing bioethics issues, policies, and practices.
Our bioethics guiding principles
Thermo Fisher’s policies and procedures reflect careful consideration and several guiding principles throughout our product research, development, manufacturing, and sales processes:
Board of Directors
As part of our Board of Directors’ oversight of the company, our Science and Technology Committee receives periodic updates on matters involving bioethics and the use of our technologies and products from our Chief Executive Officer, Chief Operating Officer, and our Chief Scientific Officer. These reports include topics such as DNA analysis for human identification and gene editing to advance precision medicine.
The Science and Technology Committee assists the Board in staying abreast of new technologies, markets, and applications of the company’s products. The Committee also monitors and evaluates trends in science and recommends to the Board emerging innovations for strengthening the company’s technological leadership. This Committee meets at least annually, or more frequently as circumstances dictate, and makes periodic reports to the Board.
Our Chief Executive Officer is responsible for the management of the company, including its bioethics policies and positions. He is supported in the management of these issues by our:
Our senior leadership is responsible for:
Our bioethics framework is monitored and managed by Thermo Fisher’s Bioethics Committee, which is committed to the socially responsible use of biotechnology to save or improve lives.
The Bioethics Committee is a cross-functional team of senior leaders who report regularly to the chairman, president and CEO. Committee members include our executive vice president, chief medical officer, chief scientific officer, and leaders representing our life sciences, clinical research and diagnostics businesses as well as legal and communications functions.
The Committee ensures we satisfy transparent, compliant, and ethical business practices and standards with unyielding integrity throughout our global operations. In particular, the Committee:
Bioethics policy and specific issue positions
We have a company-wide bioethics policy that is supplemented by internal position statements on individually identified bioethics issues.
We will strive to:
Our commitment applies across all Thermo Fisher businesses and in all countries where we do business, and to all work performed at the direction of Thermo Fisher by external organizations, consultants, and third-party vendors. We apply our policy in accordance with local, national, regional, and international standards, and the principles, regulations, and bodies that govern our areas of technological focus.
Thermo Fisher’s sales practices, product descriptions and marketing practices must always be fair, accurate and consistent with product labeling. Promotional claims must be based on valid scientific evidence and provide accurate, objective and complete information about the product. We must never promote our products for uses that have not been approved by the appropriate regulatory authority, if approval is required. Thermo Fisher believes in and practices fair trade by not prohibiting our customers or suppliers from dealing with any of our competitors as a condition of obtaining products and services from us, nor do we enter into tying arrangements where a customer is required to purchase one product in order to receive a second distinct product (provided, however, sometimes we do offer a package price for bundled products or services which can also be purchased separately).
The promotion of medical devices and diagnostic products is subject to strict regulation around the world, including by the Food Drug & Cosmetic Act, Anti-Kickback Statute and the Physician Payments Sunshine Act (and similar international regulations). Thermo Fisher employees who are subject to these regulations receive regular trainings on these topics to ensure their understanding with what is required both by the regulations and by the Thermo Fisher Healthcare Code of Conduct (“Healthcare Code”). Thermo Fisher’s Healthcare Code has been developed in accordance with the AdvaMed Code of Ethics on Interactions with Healthcare Professionals (“AdvaMed Code,” which is based on the Pharmaceutical Research and Manufacturers of America Code on Interactions with Healthcare Professionals, (“PhRMA Code”), the MedTech Europe Code of Ethical Business Practice (“MTE Code”), and other similar guidance, which takes into account the uniqueness of interactions between medical device manufacturers and healthcare professionals.
The purpose of our compliance program is to prevent and detect violations of law or company policy. Our program consists of written policies and procedures that are overseen by compliance officers within each operating group. Extensive training and education is provided on an annual basis via both web-based and live training. Employees are encouraged to report any issues to their Human Resource Department, Legal or via an Ethics Hotline. Thermo Fisher has adopted policies and procedures to address Healthcare Code violations which can lead to disciplinary action up to and including termination. As the HHS-OIG Guidance recognizes, however, the implementation of such a program cannot guarantee the elimination of improper conduct. It is Thermo Fisher’s expectation that all employees will adhere to our compliance program as well as with all applicable laws, regulations and policies.
Thermo Fisher recognizes the importance of maintaining the trust and confidence of our customers and colleagues. To more effectively prevent, detect and respond to information security threats, we have a dedicated Chief Information Security Officer whose team is responsible for leading Company-wide information security strategy, policy, standards, architecture and processes. Additionally, as part of its risk oversight function, the Board oversees our cybersecurity program through the Audit Committee, ensuring we have the policies and processes in place to manage evolving threats. Both the Audit Committee and the full Board receive regular reports from the Chief Information Security Officer and the Chief Information Officer on, among other things, the Company’s cyber risks and threats, the status of projects to strengthen our information security systems, assessments of our security program and the emerging threat landscape.