The Code of Conduct

The Code of Conduct is the bedrock policy supporting our Ethics & Compliance program. It applies to all employees, officers and directors, and is designed to deter wrongdoing and promote honest and ethical conduct. The Code includes our expectations surrounding fair business practices, including anticorruption, handling of actual or apparent conflicts of interest; appropriateness of our public disclosures; compliance with applicable laws and regulations; and protection of the Company’s assets. The Code also describes our commitments to society and stakeholders, including our approach to product quality and safety, our commitment to the basic human rights principles outlined in the UN Universal Declaration on Human Rights, and our efforts to tackle modern slavery.

Other Key Policies

In addition to our Code of Conduct, we maintain additional policies and procedures that provide specific requirements governing the day-to-day behavior of our personnel. Among other things, these policies ensure that we develop, promote and sell products in responsible and ethical manner.

  • Our Global Anti-Bribery Policy establishes our commitment to complying with anti-bribery and anti-corruption laws in all countries in which we operate.
  • Our Business Ethics Reporting Policy describes the way in which employees, contractors and third-parties can raise concerns regarding a variety of matters, including violations of the Code of Conduct or other company policies, violations of healthcare laws, and accounting or auditing matters.
  • Our Global Policy on the Protection of Personal Information outlines our commitment to complying with The EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. Data Privacy Framework (UK Extension to the EU-U.S. DPF), and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) including the principles governing the privacy rights of individuals who entrust their data to Bausch Health and the protection of Personal Information by Bausch Health, their affiliates, and third parties working on behalf of Bausch Health.
  • Our US Healthcare Compliance Policy outlines the legal and ethical standards under which we operate in the United States, and it cross-references specific policies and SOPs addressing US product promotion, the provision of meals and educational items to healthcare providers, medical information requests, and similar topics.
  • As a publicly-traded company, our Insider Trading and Black Out Policies ensure that individuals only trade in Company securities when permitted by applicable law, and never when in possession of material non-public information.
  • Each of our markets maintains policies ensuring ethical review and approval of promotional materials . Globally, we promote our pharmaceutical products in a manner consistent with the WHO Ethical Criteria for Medicinal Drug Promotion , as well as all applicable laws and industry codes.


Bausch Health periodically provides items to healthcare providers that may be subject to public disclosure under relevant transparency laws. These may include clinical trial reprints, modest meals associated with an informational presentation, educational items, and similar transfers of value where permitted by law. We also periodically hire healthcare professionals to provide bona fide consulting services in support of our development and promotion of our products.

Bausch Health is committed to publicly disclosing these payments in the United States and in other markets with applicable transparency legislation. We maintain rigorous policies to ensure that transfers of value to healthcare professionals are appropriate, justified and documented. Click here for information regarding all reportable transfers of value to US healthcare professionals. Bausch Health does not offer payments or any other transfers of value to healthcare professionals as an inducement or reward for recommending a particular product or course of treatment.

Responsible Research & Development

Bausch Health maintains comprehensive policies surrounding our research and development activities. These policies require all company-sponsored research to comply with applicable U.S. federal health care program and FDA requirements, including GCP, as well as all applicable local laws, regardless of where the research takes place. Click here to learn more about our policies surrounding ethical clinical trial practices and access to clinical study data.