Management Approach

BD holds itself to the highest standards of business conduct. Our commitment extends beyond compliance with the law to a firm belief that to become a great company and to deliver value to our customers, associates, shareholders and communities, we must be fair, honest and ethical in our business practices and personal behavior at work. We seek professional, competent people who will make the right decisions in difficult situations. How we do business and how we treat others define BD to the rest of the world. It is important that BD is known for the quality of our products, the integrity of our people and our high standards of business conduct.

Confidential Grievance System

The BD Business Conduct and Compliance Guide states that associates can raise any question or voice any concern about any legal or ethical issue without fear of discipline or loss of a job, when they are acting in good faith.

The BD Ethics Office maintains an ethics page on the BD intranet that provides information about the Company’s ethics policies and practices. In addition, the Ethics Office has established the ETHICS HELPLINE, managed by an independent provider, which is available to all associates worldwide, 24 hours a day, 7 days a week. The Ethics Office answers all inquiries. Questions may be raised without giving one’s name, if that is preferred, and all inquiries are regarded as strictly confidential. Translation services are available for non-English speakers.

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Procurement Practices

BD includes social and environmental criteria in our finished goods supplier questionnaire. For more information, see Managing Supplier Impacts section.

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Non-discrimination

BD has policies in place regarding discrimination because of race, color, religion, age, sex, creed, national origin, ancestry, marital status, familial status, affectional or sexual orientation, disability, military eligibility, veteran status or HIV/AIDS status.

Policy on Harassment

BD is committed to maintaining a workplace free from discrimination and harassment. The Company does not tolerate harassment of individuals because of their race, color, religion, age, sex, creed, national origin, ancestry, marital status, familial status, affectional or sexual orientation, disability, military eligibility, veteran status or HIV/AIDS status.

HIV/AIDS Workplace Policy

BD’s HIV/AIDS Workplace Policy is based on a desire to protect basic human rights, preserve the integrity of our workforce and respond to what we recognize as a global challenge. The purpose of this policy is to ensure that any associate who is HIV positive or who has AIDS is provided with a work environment based on dignity and respect and free of discrimination or harassment.

• Tolerate discrimination against or harassment of any associate who has HIV or AIDS
• Test for HIV/AIDS for the purposes of hiring or continued employment

• Provide healthcare benefits in a non-discriminatory way
• Assess the potential impact on BD associates and operations in regions where HIV is a significant local health issue
• Make reasonable accommodations (in accordance with local law) so associates may remain employed as long as is practical
• Maintain medical confidentiality

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Security Practices

Local management determines the type of training required for security personnel. For example, as part of the contract for security services at BD headquarters in Franklin Lakes, New Jersey, every security officer takes a training course entitled "Security Officer Basic Course" and is required to pass a written examination prior to on-site placement.

In addition, all security guards undergo thorough background checks, including a drug test, an alcohol test, a criminal record search (state and county), a credit check, a Department of Motor Vehicles check, an employment history check, personal references check, an education check, a military history check and personality tests.

In June 2007, the State of New Jersey began mandating that all security officers working in the State of New Jersey be licensed, certified and trained by a State Certified Security Instructor. All security officers at BD’s headquarters have undergone the required 24 hours of classroom training and are certified by the State of New Jersey. The training covers a range of topics, including homeland security and counter-terrorism, communications and emergency response, gang awareness, ethics and professional conduct, report writing, limits on use of force and detention of suspects, theft prevention, and First Aid, cardiopulmonary resuscitation (CPR) and automated external defibrillator (AED) awareness.

BD is also an approved certified member of C-TPAT (Customs Trade Partnership Against Terrorism) program by U.S. Customs Border Protection (CBP). As a certified member, BD is entitled to faster clearances and fewer cargo exams, allowing a more efficient global supply chain. From July to October 2006, CBP personnel conducted audits at BD headquarters, as well as the Company's Swedesboro, New Jersey distribution center, the BD Plymouth manufacturing facility and transportation-shipping vendor locations.

In February 2007, BD was officially validated by CBP and was awarded third-tier status. Third-tier status is granted to companies that demonstrate best practices in every phase of their global supply chain security. It conveys the highest level of benefits, and third-tier C-TPAT members are subject to zero inspections for security. This allows BD to expedite imported shipments through U.S. ports as well as accelerate cross-border shipments between Mexico and Canada. Currently, only 300 companies from a pool of more than 9,000 C-TPAT members have been granted third-tier status. By achieving third-tier status, BD has saved millions of dollars per year by eliminating delay time at the docks and reinspections. BD continues to monitor, audit and enhance our Global Supply Chain Security throughout the world to ensure we maintain our validation.

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