BD promotes associate compliance to internal policies as well as legislation and regulations through our Business Conduct and Compliance Guide and through “Doing What is Right,” a mandatory compliance training program. To measure our progress, BD conducts ongoing audits of the areas covered by the Guide. In addition, a group of associates in managerial and other particularly sensitive positions are asked to certify their understanding of, and compliance with, the principles of this Guide and related BD policies.

The “Doing What is Right” program coordinates compliance activities worldwide and helps promote our Core Values and culture of integrity. Associates are required to recertify annually that they have participated in the training; they will periodically receive additional required courses.

Enterprise Compliance at BD is built on the foundation of all compliance functions within the Company. The Compliance Committee provides guidance and direction, with leadership and coordination by the Chief Compliance Officer. Membership of the committee includes senior management across the Company and key departments, reflecting the importance of compliance to BD.

Compliance Committee

Office of the CEO (CEO, Vice Chairman and Chief Financial Officer, four Executive Vice Presidents)

Vice President - Finance

Vice President, Public Policy and Corporate Secretary

Ethics Office

Financial Operations and Treasury

Human Resources

Information Technology

Internal Audit

Regulatory Affairs

Tax

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