
Doing what’s right, not just what’s required
We’re committed to high ethical and business standards and expect all our employees to behave honestly and with integrity in every part of our business. We have embedded these principles into our ethics and compliance program and Code of Conduct.

Our program
Our global Ethics and Compliance program, led by the Chief Ethics and Compliance Officer, exists to promote ethical conduct and compliance with local laws and regulations. To ensure our program reaches all employees, members of our Global Ethics and Compliance team support the Chief Ethics and Compliance Officer in implementing and evaluating Medline’s Ethics and Compliance program.
The Ethics and Compliance program includes oversight and enforcement of Medline’s Code of Conduct as well as compliance policies and procedures managing Medline’s anonymous reporting hotline, Open Talk, training and communication, and auditing and monitoring.
The Medline Code of Conduct
Our Code of Conduct is the foundation on which our Ethics and Compliance program is built. The Code defines our core values and principles that govern our relationships with government agencies, customers, healthcare providers, competitors and each other. It covers a wide range of topics, including anti-discrimination, workplace safety, conflicts of interest, employee privacy, data protection, health care compliance, political participation, anti-bribery and anti-corruption. The Code aims to protect everyone and everything involved in our business as we strive to assist our customers.
Live by the Code
From our Code of Conduct, these are some of the guiding principles we expect every Medline employee to follow:
- Act with integrity in all that you do.
- Watch for situations that seem unethical or could violate the spirit of the Code.
- Report suspected violations of the Code, compliance policies, or local laws and regulations to the Ethics and Compliance team.
- Cooperate fully in any investigation or audit of business practices, possible ethical violations, or illegal conduct, and.
- Ask questions and consult with the Ethics and Compliance team if you have concerns that a business activity may be unethical, illegal, or may violate the Code or other compliance policies.
Compliance and charitable donations
Medline wishes to give back to the community and help those in need by contributing to a variety of worthy causes. Ethics and Compliance helps ensure the charitable donations approach is in line with Medline’s Code of Conduct by:
- Confirming that all charitable donations align with Medline’s overall healthcare and philanthropic objectives and that the receiving organization uses the donations for charitable or philanthropic purposes only
- Making charitable donations to organizations that share Medline’s commitment to D&I
- Ensuring that charitable donations are given at arms-length and not as a way to receive potential benefits or business gain
Protecting human rights throughout our supply chain
Modern slavery, forced labor and human trafficking are critical human rights issues that require continuous vigilance. Medline is committed to implementing systems and controls to prevent these phenomena from occurring to the best of our abilities. We conduct monitoring in our own operations, as well as those of our suppliers, to prevent and address abuses of workers’ fundamental human rights. Our Supplier Code of Conduct and Modern Slavery Transparency Statement reiterate our commitment to the protection of human rights throughout our global supply chain.
In 2020, Medline formalized an Ethical Sourcing Program to consolidate resources and build on existing initiatives with the goal of ensuring respect for all workers throughout our global operations and supply chains. This new program involved review and enhancement of our existing ethical sourcing policies and procedures, as well as ensuring we are benchmarking ourselves against the United Nations Guiding Principles on Business and Human Rights (UNGPs) and other international best practices. These efforts are designed to help our company achieve meaningful growth toward the fulfillment of the UN Sustainable Development Goals. Medline has formalized our standards for our supply chain in the Medline Supplier Code of Conduct.
By taking a risk-based approach to ethical sourcing, we focus our efforts where the greatest risks exist—and where Medline can assert leverage to achieve positive change. In the 2021 calendar year, Medline’s ethical sourcing audit team conducted over 520 audits globally.
The 11 pillars of our Ethical Sourcing Program:
- Roles and responsibilities
- Ethical sourcing standards
- Risk assessment
- Supplier engagement
- Social compliance audits
- Grievance mechanisms
- Remediation
- Customer engagement
- Training and capacity building
- External reporting and communication
- Assessing effectiveness
Standards we follow globally
Medline is committed to being law-abiding, honest and trustworthy in all our business dealings. We practice good business by adhering to the highest standards to protect our company and the planet we call home. We follow all legislation and regulations in the countries where we operate and comply with industry-leading standards.
MedTech Europe
As a member of the MedTech Europe trade association, we are required to comply with its Code of Ethical Business Practice. In compliance with MedTech Europe’s code, we avoid conflicts of interest when balancing our customer relations and charitable work. We also do not donate cash or products to, or at the request of, healthcare providers in Europe.
Advanced Medical Technology Association
As a member of the Advanced Medical Technology Association (AdvaMed), we support its mission to advocate for the highest ethical standards and patient access to safe and leading medical technologies, and comply with AdvaMed’s Code of Ethics on interactions with US Health Care Professionals.