Becton Dickinson Business Conduct and Compliance Dennis

Becton Dickinson

Business Conduct and Compliance

Dennis Santucci

Based on discussions which you and I have had over the preceding months, the issues of business conduct and compliance are of the utmost importance to you and your team which spearhead our Chinese operations. Let me first assure you that Becton Dickinson's primary concern is "to do what is right" (Case Study. N.D.). Further, "a systematic focus on values, ethics, and sound business practices is an essential management tool that helps us decentralize responsibility while maintaining aggressive performance goals" (Case Study. N.D.). I trust the following information will prove invaluable to you in the coming days.

Unquestionably there are considerable gray area scenarios which continue to produce obturations to successful ethical and business practices around the globe for Becton Dickinson. From Asia to Europe to South America, controllers such as you are looking for concrete rules and decision making processes which will facilitate sound and ethical revenue producing deal making. Two of your concerns: "a physician considering BD's diagnostic equipment for his hospital laboratory would like to go for instrument training in California and afterwards to visit Disneyland with his family, and a purchasing official employed by a customer organization wants a processing fee of two percent of the sales price in cash prior to placing his company's order with BD" (Case Study. N.D.); are prime examples of the difficulties in determining the appropriateness of "approving payments for sales, marketing, and other expenses" (Case Study. N.D.). Becton Dickinson is intent on growing market share in the 100 billion dollar market for medical supply technology, a market which is growing at seven percent per year (Case Study. N.D.). In this context the company understands the need to build relationships with: suppliers, distributors, and customers to achieve an "increase of ROE to 20% by 1997 and annual sales growth to 10% by the end of the year 2000" (Case Study. N.D.). Let me emphasize however, that the Becton Dickinson Business Conduct and Compliance Guide prohibits any conflict of interest and the improper use of business courtesies.

Analysis

It is likely that in the next month the Global One Company Operating Group will provide the guidance on gray area business practices: "the acceptability of certain gifts, gratuities, and entertainment costs" (Case Study. N.D.); which you have articulated. The operating group has carefully studied the Becton Dickinson compliance guide to clarify any ambiguities on such matters as: "appropriate levels of entertainment and business hospitality, dealing with special requests from customers and potential customers -- some of whom were government officials, dealing with special requests from government regulatory officials, and the acceptability of certain distributor practices" (Case Study. N.D.). In addition, given the tide of anti-corruption and bribery actions taken by worldwide government agencies and companies, as well as the stringent requirements of the U.S. Foreign Corrupt Practices Act; the operating group will make significant clarifications on policy designed to facilitate greater compliance.