Business Integrity HelpCenter Questions & Answers

EthicsPoint is an independent company that provides secure, confidential telephone and Web-based systems for people who want to report a concern or ask a question about St. Jude Medical’s business conduct. St. Jude Medical is one of many companies that use EthicsPoint for this service because we believe people will be more comfortable reporting a concern or asking a question through an independent, professional, third party. EthicsPoint provides service 24 hours a day and offers translators for more than 150 languages for callers who do not speak English or who are more comfortable using their first language to describe their concern or question.

• Provides confidential telephone and online options to report concerns or ask questions about St. Jude Medical's business conduct
• Protects the identity of the person making the report or asking the question
• Provides translation services
• Transmits reports that originate from or involve activities in Belgium, France, Germany, the Netherlands, or Spain to Stephanie Puyraud, who is based in Brussels, so St. Jude Medical can take appropriate action
• Transmits all other reports to St. Jude Medical's Business Integrity Officer so St. Jude Medical may make appropriate inquiries
• Allows St. Jude Medical to communicate with anonymous reporters by serving as an intermediary that relays follow-up questions and answers, along with case resolution

EthicsPoint does not answer questions or take action to resolve a concern about St. Jude Medical's business conduct. EthicsPoint is only able to communicate information between St. Jude Medical and the person reporting the issue.

Do not call EthicsPoint if there is an immediate threat of physical harm or damage to property. Contact your local management or emergency services (such as 911 in the U.S.), whichever is appropriate for the situation.

If you are comfortable doing so, speak with your local management or human resources department. Usually, internal concerns can be resolved more quickly and satisfactorily when you resolve them locally. If you are not comfortable raising your concern or question with local management or human resources or if you believe your concern or question has not been satisfactorily addressed, call the Business Integrity HelpCenter or create an online report. Call 1.800.254.0456 in the U.S. or Canada or see the International Toll-Free Dialing Instructions.

Because of the data protection and privacy requirements for many European Union countries, the types of issues that may be reported in some countries are very limited. For example, in some countries, only issues related to certain financial and accounting misconduct may be reported. Also, in the other European Union countries, people who report certain types of issues, such as concerns about a manager, may be told to contact their local Human Resources department rather than using the Business Integrity HelpCenter.

Report all suspected violations of law, contractual obligations, and company policies, including the St. Jude Medical Code of Business Conduct.

For example, make a report if:

• Your supervisor directs you to falsify information in a report
• You become aware of an employee who is using company systems to operate a personal business
• You notice a contractor who works onsite loading office equipment into his car
• You overhear someone offer a physician a consulting or research agreement to maintain her loyalty to St. Jude Medical
• You learn about illegal or unethical conduct by a St. Jude Medical third party sales representative

Issues that may be reported by people in some European Union countries may be limited to certain activities, such as financial and accounting misconduct. All other issues must be reported to local management or human resources. If an employee submits a report that he or she knows is false or for malicious purposes, then they may be sanctioned and their identities may not be kept confidential.

No. St. Jude Medical strictly prohibits retaliating against someone who reports concerns or participates in an investigation in good faith. In fact, if another employee punishes you for making a good faith report, that employee is subject to disciplinary action.

If you believe you are being retaliated against because of reporting a concern or assisting with an investigation, immediately contact your local human resources department, contact the St. Jude Medical Business Integrity Office, or submit a report to the St. Jude Medical Business Integrity HelpCenter. Note: You must provide your name, as we cannot respond to anonymous retaliation allegations through the HelpCenter.

European Union (EU) countries have concerns about reporting mechanisms like the Business Integrity HelpCenter. As a result, employees who are based in EU countries have rights that other employees do not have.

EU employees have a right to be notified if they are identified in a HelpCenter report unless we reasonably determine that providing the notice could jeopardize our ability to effectively investigate the allegations. If an EU employee is identified in a HelpCenter report, we will promptly notify the EU employee unless we believe doing so would affect our ability to investigate the allegations. If we do not notify the EU employee right away, we will notify him or her once we can do so without affecting the investigation.

At the time we notify an EU employee that he or she is identified in a HelpCenter report we will also provide a description of the report as it relates to the employee.

EU employees will also be informed about who receives internal reports, such as internal investigation reports, in which they are identified.

We will regularly monitor the information included in HelpCenter reports that are initiated in or involve activities in an EU country. As we identify information included in HelpCenter reports that is not necessary for investigating possible misconduct or other legitimate business needs, we will delete or archive the unnecessary information, including the names of identified EU employees. Any archived information will be retained in paper in a secure location. It is unlikely we will delete entire HelpCenter reports, but we may remove most of the information about the HelpCenter report and retain a note that explains why the information was deleted and if it was archived.

St. Jude Medical cannot promise that someone who self reports misconduct will avoid disciplinary action. However, if you report your own misconduct St. Jude Medical will consider imposing less severe disciplinary action than if it discovered in another way.

Call the HelpCenter or make an online report (see below) to report a business conduct concern or question involving St. Jude Medical.

Calling the St. Jude Medical Business Integrity HelpCenter
Call 1.800.254.0456 in the U.S. or Canada or see the International Toll-Free Dialing Instructions.You will not be charged for the phone call. In most countries, the phone number is toll free. If a toll-free telephone number is not available, we provide a telephone number for which the person answering the call will accept collect calls or reversed charges.

Calls to the HelpCenter are answered in English. If you want to make your report in a different language, tell the specialist who answers the call what language you want to use and they will arrange for an interpreter to join the call.

Specialists are available 24 hours a day to take reports by telephone.

Yes. St. Jude Medical's Business Integrity HelpCenter is intended to provide information and guidance. Typically, you should first ask your manager, your division's compliance professional (if there is one), your division's legal department, or, if appropriate, your division's human resources department. If you are uncomfortable doing so or are dissatisfied with the response you receive, submit a report with your question to the Business Integrity Office by using the HelpCenter.

Generally no, you do not have to give your name, but we hope that our policy against retaliation will reduce any concerns you have about identifying yourself. Because of the data privacy laws in European Union countries, people submitting reports from European Union countries are encouraged to provide their name and rely on the confidentiality discussed in response to the next question.

We often need additional information to fully investigate a concern or respond to a question. If you submit a report about a concern or question without providing your name, be sure to follow up online or by telephone using the report key and password established when you initially submit the report.

Occasionally we receive anonymous reports about grievances employees have with a supervisor or another person. There is very little we can do to address such grievances on an anonymous basis. In such cases, we advise the anonymous caller to contact his or her local human resources department to resolve the grievance.

EthicsPoint, St. Jude Medical's Business Integrity HelpCenter vendor, does not trace phone calls or use caller ID. Also, if you submit an online report, there is a secure Internet portal that does not trace or show user screen names and EthicsPoint removes Internet addresses. EthicsPoint will not use the information it receives for any purpose other than to provide your report to St. Jude Medical.

The St. Jude Medical staff responsible for investigating reports of misconduct will make every reasonable effort to maintain the confidentiality of your name during the investigation.

The EthicsPoint staff who answer the phone are trained to ask questions that will help provide St. Jude Medical with the information it needs to investigate and resolve the concerns you identify or questions you ask.

EthicsPoint staff cannot answer your questions or resolve any concerns. They prepare a written report of the information you give and provide it to St. Jude Medical's Business Integrity Office to follow up and resolve.

Except for reports from certain EU countries, St. Jude Medical’s Business Integrity Officer receives all reports submitted to the HelpCenter. Based on the type of concern or question, St. Jude Medical’s Business Integrity Office either resolves the report or assigns it to the appropriate person for resolution, which is often a division’s legal or human resources department. All allegations of misconduct are investigated if we receive enough information to conduct an investigation.

The report is provided to Stephanie Puyraud if the reporter indicates the report is initiated in or involves activities in Belgium, France, Germany, the Netherlands, and Spain. Stephanie is a member of the International Division’s legal department and is based in Brussels.

Usually, questions are answered within a few days. Some investigations are completed quickly; others take several weeks. It depends on the nature of the allegation and the necessary investigation. The fact that an investigation is taking several weeks does not mean St. Jude Medical does not take the allegation seriously or is not aggressively investigating the allegation.

At the end of your telephone call or online report, you will receive a report key and create a password. You will be told to contact the Business Integrity HelpCenter by telephone or online to monitor progress on your report and learn about any additional information St. Jude Medical needs to respond to your concern or question.

A final response is always available to you through the Business Integrity HelpCenter. If you elected to remain anonymous, you must contact the Business Integrity HelpCenter to receive St. Jude Medical's response.

If you identified yourself, the person who had primary responsibility for resolving your concern or answering your question may directly notify you of the results.

St. Jude Medical will decide whether allegations of misconduct have been proven. If St. Jude Medical says it cannot prove your allegation, it does not necessarily mean the allegation is not true, it may just mean there is not enough evidence to prove the allegation is true. If an allegation cannot be proven, St. Jude Medical may notify you that it will investigate further if you can provide additional information.

If St. Jude Medical determines that misconduct has occurred, we will usually notify you that the investigation is complete and appropriate action has been or will be taken. Due to confidentiality and privacy concerns, including employees' privacy rights, you may not receive details of findings from the investigation or actions taken, including any disciplinary action taken against another employee for misconduct. The Business Integrity Office may also ask you to notify St. Jude Medical if you believe the problem continues after it was supposed to have been resolved.

If you have a question about St. Jude Medical's Business Integrity HelpCenter or its Business Integrity Program, contact the Business Integrity Office or the Business Integrity Officer, Vickie McCormick at 651.766.3011 or businessintegrityoffice@sjm.com.