Baxter International Inc. established and operates its Third Party Anti-corruption Program (due diligence program) to support the company’s ongoing commitment to meet all its legal and compliance obligations. Baxter’s ethical reputation is crucial to its business success and the Company therefore takes compliance with global anti-corruption laws very seriously. As a global company, Baxter is subject to the laws of all countries in which it operates. The Third Party Anti-corruption Program is designed to ensure that Baxter is in compliance with anti-corruption laws.

Your company may be asked to complete a Due Diligence Questionnaire, a short training module or an Annual Certification Questionnaire to assure Baxter that its Third-Party partners comply with all applicable laws, rules and regulations. Completion and submission of these items is mandatory for Baxter to be able to assess and implement its third party relationship with your business. In addition, you may be contacted by our due diligence service provider, Deloitte.

INSTRUCTIONS FOR QUESTIONNAIRES

  1. Please respond to the best of your ability to each question.
  2. The Third Party agrees to immediately report to Baxter any suspected violations of the Ethics & Compliance Standards for Baxter Suppliers, the terms of its agreement with Baxter, or any other relevant laws, rules, regulations and policies in relation to its agreement with Baxter. You can reach Baxter’s Helpline at this link: https://secure.ethicspoint.com/domain/media/en/gui/43263/index.html
  3. Third Parties must disclose any actual as well as any apparent conflicts of interest to Baxter’s management for approval or discussion of potential accommodations or workarounds. Baxter reserves the right to take any necessary actions for the failure to do so. If Baxter management approves an apparent or actual conflict, the approval decision must be documented.

DEFINITIONS

"Government Official" means any individual currently acting in any of the following capacities and has direct or indirect power over Baxter’s business:

  1. Any elected official, civil servant, military personnel, officer or employee of a government (including sub-national and local governments) or any department, agency or instrumentality thereof;
  2. Any person acting in any official capacity on behalf of a government or any department, agency or instrumentality thereof;
  3. Any officer or employee of any entity owned in whole or in part by a government;
  4. Any officer or employee of a public international organization such as, but not limited to, the World Bank, World Health Organization, or the United Nations;
  5. Any political parties, political party officials or candidates for political office in a government;
  6. Any member of a royal family with official or unofficial power over any aspect whatsoever of a Non-U.S. Government, including its decision-making process, executive function, administration, or finances, including any direct or indirect power over Baxter’s business;
  7. All close relatives of any of the above-described categories, including spouses, children, siblings or other immediate family members.
In many countries, HCPs are public employees and as such are considered Government Officials.

PRIVACY NOTICE (Effective 30 October 2022)
This Privacy Notice will provide you with information on the Personal Information that Baxter International Inc., One Baxter Parkway, Deerfield, IL USA 60015, Toll Free: 1-800-422-9837 Local United States: 1-224-948-1812 and the local Baxter entity which engages your company ("Baxter") collects from you as part of its Third-Party Anticorruption Program. For any information about local Baxter entities please consult your local Baxter contact.

This Privacy Notice is intended to describe and cover all processing activities related to Baxter’s Third Party Anticorruption Program which includes completion and submission of a Due Diligence Questionnaire (DDQ), performance of an On-line Training Module and completion and submission of an Annual Certification Questionnaire (when requested).

The Privacy Notice applies to you, your Company and your Company’s principals, shareholders, directors, owners and key managers whose data you share with us ("principals"). By submitting a DDQ and/or completing the On-line Training Module and/or submitting the Annual Certification Questionnaire, you represent that you have whatever legal authority may be necessary for the transfer, processing and use of all personal/business data provided to Baxter for the activities related to Baxter’s Third Party Anticorruption Program. You further represent that you have provided this Privacy Notice to all persons whose data is shared with Baxter for the purposes of Baxter’s Third Party Anticorruption Program and that they have given their written consent to you for Baxter to process their data as described herein, which you will make available to Baxter upon request.

This Privacy Notice provides you with information on how Baxter will process your and/or your Company’s or company’s principals’ Personal Information and how you can exercise your rights regarding your Personal Information.

What personal information we collect
We may obtain directly from you and/or only from publicly available data bases the following categories of Personal Information about you, your Company or your Company’s principals, shareholders, directors, owners and key managers: Company/business address, business phone or fax number, company name, title, email, as well as information from publicly available data bases such as company financial information, education, familial relationships, career details, corporate interests, high risk individual’s designation, civil and criminal litigation records for the above individuals on public data bases, as far as available in the specific countries and subject to local rules about access to civil and criminal litigation records.

Why we collect your personal information
Baxter will collect your Personal Information and use it for the purposes of meeting all its legal obligations by reference to its Third Party Anticorruption Program and based on our legitimate interest to comply with the antibribery/anticorruption laws. The Third Party Anticorruption Program is designed to ensure that Baxter is in compliance with the anti-bribery/anti-corruption laws enacted in each country where Baxter conducts business, such as the United States Foreign Corrupt Practices Act, legislation enacted in accordance with the OECD United Nations Convention Against Corruption, the UK Antibribery Act, the French Sapin II law and in the United States, the United States Anti-Kickback Statute, Stark Laws and Federal False Claims Law.

Baxter will process your Personal Information on the above basis and will decide whether to enter into or continue any contractual relationship with you or your Company based in part on the responses to the DDQ, the completion of the On-line Training Module, and any Annual Certification Questionnaire. If Baxter determines that you have provided any false, incomplete, or misleading statements, Baxter may not enter into or may immediately terminate any contractual relationships with you or your Company or modify such contracts to prohibit any dealing with government officials and take any other action allowed by contract or applicable law.

Who may receive your personal information
Baxter will share your Personal Information or make it available with Baxter employees on a need to know basis.

Sharing your personal information with our service providers
Baxter uses service providers and other business partners to help us process your Personal Information. Your data will be shared with Deloitte Financial Advisory Services LLP and one or more members of the Deloitte Touche Tohmatsu Limited (DTTL) global network of member firms, including Deloitte Financial Advisory Services India Private Limited on a need to know basis in order to verify the information provided by your Company and to conduct background/due diligence checks in publicly available data bases. Your data may be also shared with Diligent Corporation who is the owner of this Securimate platform in order to perform maintenance or technical support on the Third Party Anticorruption Program platform. Your data may also be shared with other vendors such as, including without limitation, audit firms, or other third party providers that support the implementation of the Third Party Antibribery Compliance Program.

Baxter has data processing agreements with its business partners to ensure they provide an adequate level of protection for your Personal Information. These entities are authorized to use your Personal Information only as necessary to provide these services to us.

How long we keep your personal information
Your Personal Information will only be kept for as long as we reasonably consider necessary for achieving the purposes set out above, or for as long as we are legally required to keep it.

International data transfers
Baxter is a global company and therefore uses global subcontractors as well as systems and applications. We may transfer your Personal Information to our affiliates and subcontractors located outside of the European Union and in jurisdictions which may provide a different level of privacy protection. If we do so, we will take measures to ensure that all recipients provide an adequate level of data protection. When transferring Personal Information between corporate entities, Baxter relies on various legal transfer mechanisms (e.g., standard contractual clauses) needed and implements supplementary measures, depending on the type of Personal Information and countries involved. Please contact Baxter at the contact details provide below for any questions you might have regarding the measures in place to protect your Personal Information or to request copies of the applicable data transfer agreements.

Merger or Sale
If we are involved in a merger, acquisition, or sale of our assets (or a portion thereof), it may impact how we process your Personal Information. In such an instance, we will comply with all applicable laws and treat your Personal Information accordingly.

Your rights
In certain circumstances, local data protection laws and certain local laws (including the GDPR) give you rights with respect to your Personal Information. These rights differ by country/region. These rights may include:

  • You can request access to or copies of your Personal Information, including knowing whether we hold Personal Information about you, and, if so, what kind and for what purposes. You can also request information about who has received your Personal Information.
  • You can request that we correct your Personal Information if you think it is inaccurate or incomplete or request that we erase or delete your Personal Information, unless we have a legal obligation to hold it or are otherwise permitted by applicable law to retain it.
  • You can request us to restrict the processing of your Personal Information and not delete it.
  • You can request that we provide you with your Personal Information that we obtained from you based on a contract so that you can store and re-use it for your personal use, and you can ask us to provide it to another entity.

In some countries, you also have the right to object to our using and disclosing your Personal Information for certain purposes, including our legitimate interests. If you have questions about how we determine processing for our legitimate interests or if you want to object to our processing on that basis, please contact us at privacy@baxter.com using the contact details provided below. If you believe we are using, disclosing or otherwise processing your Personal Information in a way that is not in accordance with the law you can lodge a complaint with a data protection authority in your country.

Please address your requests to exercise your rights described above, or questions concerning this Notice or the processing of your Personal Information, to the Data Protection Officer as follows:

Email to: privacy@baxter.com
Telephone: Ethics and Compliance Hotline at
https://secure.ethicspoint.com/domain/media/en/gui/43263/index.html
Mail to: Baxter Healthcare Corporation
Baxter International Inc
ATTN: Data Protection Officer

We will handle any request to exercise your rights in accordance with applicable law. Please note that depending on the circumstances, some of the above rights may not be applicable.

Changes to this Privacy Policy
We may periodically make changes to this Privacy Notice. Those changes will be reflected in the Privacy Notice the next time you log into the system. We encourage you to periodically review this Privacy Notice for the latest information on our privacy practices. The date this notice was last revised is located at the top of this notice.

CONSENT

[ONLY FOR JURISDICTIONS THAT REQUIRE CONSENT]

I have read the Privacy Notice. I understand its contents and expressly and voluntarily consent to the application of its terms (including those regarding the collection, processing and use of my Personal Information, by Baxter, and the international transfer of my Personal Information to countries where data protection laws may not provide an equivalent level of protection to the laws of my home country for the purposes and in the manner described in this Privacy Notice) in connection with Baxter’s Third-Party Anticorruption Program.

By submitting the Due Diligence Questionnaire, the training module and/or the Annual Certification form to Baxter, I hereby:

  • give my consent to Baxter and its affiliates to collect, process and use my Personal Information for the purposes and the retention periods set out in the section titled "Why we collect your Personal Information" of the Privacy Notice.
  • give my consent to Baxter and its affiliates to disclose my Personal Information to Baxter’s affiliated and unaffiliated third-party service providers for the purposes set out in the section titled "Sharing your Personal Information with our service providers" of the Privacy Notice.
  • give my consent to the international transfers of my Personal Information to Baxter’s affiliates for the purposes and in accordance with the section titled "International data transfers" of the Privacy Notice.

U.S. STATE LAW SUPPLEMENT:
SUPPLEMENTAL PRIVACY NOTICE FOR U.S. RESIDENTS AS APPLICABLE

Last Revised: December 2023

Baxter International Inc. and the Baxter entity which engages your company ("Baxter," "we," "our" or "us") provide this U.S. State Law Supplemental Privacy Notice (“Supplement”) to U.S. Residents as Applicable (“Consumers,” “you”) to provide you with additional information, as required by applicable state law, on how we use and disclose your information that we collect from you as part of our Third-Party Anticorruption Program.

If you would like to receive a copy of this Supplement in an alternate format (e.g., printable) or language, please contact us using the information provided below.

If we make material changes to this Supplement, we will post a notice on our site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

1. Personal Information Collected and Disclosed
“Personal Information” as used in this Supplement means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household. The Personal Information Baxter collects from you is listed in the Privacy Notice. In particular, Baxter will collect and disclose the below listed statutory categories of Personal Information from Consumers for the following described purposes.

Categories of Personal Information Collected & Disclosed
We may obtain directly from you and/or only from publicly available data bases the following categories of Personal Information about you, your Company or your Company’s principals, shareholders, directors, owners and key managers: Company/business address, business phone or fax number, company name, title, email, as well as information from publicly available data bases such as company financial information, education, familial relationships, career details, corporate interests, high risk individual’s designation, civil and criminal litigation records for the above individuals on public data bases, as far as available in the specific countries and subject to local rules about access to civil and criminal litigation records. Note that publicly available information is not considered to be Personal Information, unless otherwise provided under applicable U.S. privacy laws.

Categories of Personal Information Collected & Disclosed

  • Identifiers - A real name, company/business postal address, company/business fax number.
  • Personal information categories - A name, address, telephone number, title, education, employment, employment history. Some personal information included in this category may overlap with other categories.
  • Protected classification characteristics - Gender.
  • Professional or employment-related information - Career details, corporate interests.
  • Education information – Education information that is not publicly available personally identifiable information.
  • Inferences drawn from other personal information – Profile reflecting your characteristics.

Please see the section entitled, “What personal information we collect” in our Privacy Notice above for a description of how Baxter collects this Personal Information.

The above listed categories of Personal Information are disclosed to the categories of third parties discussed in the section entitled, “Sharing your personal information with our service providers” and “International data transfers” in our Privacy Notice above.

The above listed categories of Personal Information are collected and disclosed for the business purposes stated in the Privacy Notice (section entitled, “Why we collect your personal information”) and retained as stated in the Privacy Notice above (section entitled, “How long we keep your personal information”).

2. Sale, Cross-Context Behavioral Advertising, Targeted Advertising
Certain state laws regulate the “sale” of Personal Information, which may include not only the traditional selling of data, but also many sharing arrangements where the recipient can use the Personal Information that they receive for the recipient’s own commercial purposes. State laws may also regulate the disclosure of Personal Information to third parties for cross-contextual behavioral advertising (referred to as “sharing” under the California Consumer Privacy Act of 2018 or “targeted advertising,” as such practice is more commonly referred). Please note, that for purposes of this Supplement, “sale” may be broadly defined to include exchanges of Personal Information for monetary or other valuable consideration.

We do not “sell” “share,” or use your Personal Information for purposes of targeted advertising. We also do not knowingly “sell” or “share” the Personal Information of individuals under the age of 16.

3. Your Privacy Rights
Depending on your location, you may be afforded certain privacy rights. In general, you may exercise your privacy rights with respect to your Personal Information as set forth in the table below by following the instructions set forth below in this Supplement. Please note that applicable law sets forth a process to follow when evaluating your request, and there are also some exceptions to these rights.

Privacy Rights Description
Notice You may have the right to be notified of what categories of Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared.
Right to Know/Access You may have the right to confirm whether your Personal Information is being processed. You may have the right to request that we disclose to you what Personal Information of yours has been collected, used, disclosed, and sold or shared, including, depending on your location:
  • The categories of Personal Information collected about you;
  • The categories of sources from which the Personal Information is collected;
  • The business or commercial purpose for collecting, selling, or sharing the Personal Information;
  • The categories of Personal information, if any, that were disclosed for a business purpose or sold to third parties;
  • The categories of third parties to whom the information was disclosed or sold; and
  • The specific pieces of personal information collected about you.
Data Portability You may have the right to receive copies of your Personal Information that we have collected in a commonly used and machine-readable format.
Right to Delete You may have the right to request deletion of the Personal Information collected about you.
Right to Correct You may have the right to request the correction of inaccurate personal information that is maintained about you.
Right to Opt-Out of Sale, Cross-Context Behavioral Advertising, Targeted Advertising Certain laws may provide you the right to opt-out of the sale of your Personal Information and the use or disclosure of your Personal Information for cross-context behavioral advertising (i.e., “sharing” under the California Consumer Privacy Act) or targeted advertising. We do not use or disclose your Personal Information in these ways.
Automated Decision-Making You may have the right to request information about the logic involved in certain types of automated decision-making practices and a description of the likely outcome of processes, and the right to opt out of such processes.
Right to Limit the Use of Sensitive Personal Information You may have the right to limit certain uses of Sensitive Personal Information.
Right to Non-Discrimination You have the right to not receive discriminatory treatment if you exercise any of the rights conferred to you by law.

4. How to Exercise Your Rights
If you would like to exercise any of your rights listed above, please contact us using the information below.

You may also designate an authorized agent to make a request to exercise your rights on your behalf. In order to do so, you must contact us using the information below.

When contacting us to exercise your rights, please adhere to the following guidelines:

  • Tell Us Which Right You Are Exercising: Specify which right you want to exercise and the Personal Information to which your request relates (if it does not relate to you). If you are acting as an authorized agent on behalf of someone else, please clearly indicate this fact and indicate your authority to act on their behalf.
  • Help Us Verify Your Identity: Contact us using the information below and provide us with enough information to verify your identity. Please note that if we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.
  • Direct Response Delivery: Inform us of the delivery mechanism with which you prefer to receive our response. You may specify, for example, email, mail, or through your account (if you have one with us).

Please note that you do not need to create an account with us in order to make a request to exercise your rights hereunder.

Please contact us to appeal any decision made on your request.

5. Responses to Your Requests
Receipt of your request will be confirmed consistent with applicable law. You will generally receive a response to your request within forty-five (45) days. However, where reasonably necessary and where permitted by law, the response time may be extended by an additional forty-five (45) days, provided you are given notice of such extension first. If the information is provided to you electronically, it will be in a portable format and, to the extent technically feasible, in a machine readable, readily useable format that allows you to freely transmit this information without hindrance.

Please note that you will not be charged for making a request, provided that you make no more than two (2) requests per year. Where permitted by law, your request may be denied, for example, if your requests are determined to be unfounded or excessive (e.g., repetitive in nature), or a reasonable fee may be charged. In these circumstances, you will receive a notice regarding this denial and the reason for such denial.

6. Contact Information
To exercise one or more of your rights, or to contact us with questions and concerns about this Privacy Notice, please contact us at:

  • Email: privacy@baxter.com
  • Mail: Baxter International Inc.
    ATTN: Global Privacy Office
    1 Baxter Parkway, Deerfield, IL USA 60015
  • Phone: Ethics and Compliance Hotline: 1-844-294-5418

For additional information about Baxter’s information practices, please see the Baxter U.S. Privacy Policy at https://www.baxter.com/us-privacy
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