Sales and Marketing Managers are expected to:
• periodically reinforce this Policy through communication;
• model their conduct around this Policy and underlying ethical principles;
• ensure direct reports’ timely complete required training;
• ensure direct reports’ accurately and timely comply with internal processes established
to secure compliance to the Policy;
• encourage candor in reporting suspected violations of this Policy;
• escalate reported concerns about violations of this Policy;
• discipline those who violate this Policy or underlying ethical principles; and
• prevent retaliation against any person or entity for reporting a concern about violation of
this Policy.
Managers who retain, oversee or evaluate Business Partners are also responsible for
complying with Medtronic’s Distributor Policy and for ensuring that Business Partners:
• receive a copy of this Policy;
• are fully informed of the requirements and prohibitions of this Policy, the FCPA and other
applicable Anti-corruption Laws;
• certify compliance with this Policy; and
• receive Medtronic-approved anti-corruption training.
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