A robust annual training and awareness program helps ensure that our employees take ownership and accountability for sustaining our culture of compliance. This culture is marked by an unwavering commitment to adhere to the highest standards of ethics and integrity in all our interactions with patients, health care providers, customers, fellow colleagues and other key stakeholders.

Each year, we conduct global corporate governance training to ensure our employees stay informed, up-to-date and in compliance with our corporate governance policies which include our Code of Conduct, Business Ethics Reporting Policy, Global Anti-Bribery Policy and others.

We supplement this training with localized, risk-based training. Among other examples, we deliver targeted training to members of our sales force on ethical marketing and product promotional practices, and we train employees who participate in clinical trial activity on our policies surrounding the ethical conduct of clinical research. We also provide targeted training to other individuals whose roles are subject to heightened regulatory scrutiny or who have accountability for various higher risk business processes.

All employees are trained on the consequences of failing to comply with the requirements of Bausch Health’s compliance program, which includes appropriate disciplinary action, up to, and including, termination of employment.