Always acting with integrity

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Philips North America LLC is a part of Royal Philips and our company stands for quality, innovation, leadership and integrity. At Philips, we take our commitment to ethical behavior seriously and we expect that same commitment from everyone who works here. The Philips Ethics and Business Conduct Program formalizes that commitment and includes, without limitation, the following:

Philips General Business Principles (GBPs) sets the worldwide standard for always acting with integrity.
The Philips Code of Conduct for Interactions with United States Health Care Providers and Professionals (Philips Code of Conduct) sets specific guidelines on what is and what is not permissible with U.S. health care providers and professionals.
Simply Right further defines the obligations for our United States employee in four key areas: Employment Practices, Business Conduct @Philips, Internal and External Controls and Reporting, and Sustainability.
Financial Code of Ethics, Supply Management Code of Ethics, Whistleblower Policy, Philips Ethics Line and related ethics and compliance policies.
The Philips Healthcare Compliance Program
Philips Respironics Sleep & Respiratory Care Healthcare compliance information

Learn more about our compliance programs.

Philips North America LLC Compliance Program

Acting with integrity is at the heart of our culture, and is part and parcel of our company’s mission and vision.

While pursuing our business objectives, we aim to be a responsible partner in society, acting with integrity towards our employees, customers, business partners and shareholders, as well as the wider community in which we operate. The Philips Healthcare Compliance Program is a vital component of that commitment to the Always Acting With Integrity. Below are some of the critical elements of our compliance program:

Policies, procedures, and guidance
Policies, procedures, and guidance
Policies, procedures, and guidance

Philips has developed and distributed written compliance standards, procedures, and guidance designed to comply all relevant laws, regulations, and industry standards.

The Philips Ethics and Business Conduct Program formalizes that commitment and includes, without limitation, the following:

Philips General Business Principles (GBPs) sets the worldwide standard for always acting with integrity.

The Philips Code of Conduct for Interactions with United States Health Care Providers and Professionals (Philips Code of Conduct) sets specific guidelines on what is and what is not permissible with U.S. health care providers and professionals.

Simply Right further defines the obligations for our United States employee in four key areas: Employment Practices, Business Conduct @Philips, Internal and External Controls and Reporting, and Sustainability.

Financial Code of Ethics, Supply Management Code of Ethics, Whistleblower Policy, Philips Ethics Line and related ethics and compliance policies.

The Philips Healthcare Compliance Program (policy)
Designating a compliance officer and compliance committee
Designating a compliance officer and compliance committee

Designating a compliance officer and compliance committee

Dedicated support

Philips has designated a Compliance Officer who reports up to The Royal Philips Chief Legal Officer and reports regularly to the Board of Management on compliance issues.

Philips has a dedicated compliance committee to support the compliance program and compliance officer. The compliance committee is responsible for routinely assessing the overall compliance program’s effectiveness and providing guidance.

Philips also has a network of Compliance Officers and Administrators who are available to answer questions, conduct training and provide guidance to employees on legal compliance issues.
Conducting effective training and education
Conducting effective training and education
Conducting effective training and education

Philips provides in-person and technology assisted compliance training and education to new employees and on an annual basis to all employees.

Training and education covers key compliance areas. Among others, it includes:

Philips General Business Principles

Preventing Medicare Fraud and Abuse

Complying with the Simply Right Program
Developing effective lines of communication
Developing effective lines of communication

Developing effective lines of communication

Philips Ethics Line

Non-Retaliation Policy

Regular communications from Philips leadership
Conducting internal monitoring and auditing
Conducting internal monitoring and auditing

Conducting internal monitoring and auditing

Philips utilizes audits and other risk-assessment techniques to monitor compliance, identify high-risk areas and determine corrective action for identified problems.

Philips has policies and procedures in place to address the hiring or retention of individuals or entities excluded from participation in federal health care programs
Enforcing standards through well-publicized disciplinary guidelines
Enforcing standards through well-publicized disciplinary guidelines

Enforcing standards through well-publicized disciplinary guidelines

Philips has disciplinary processes in place for employees or contractors who violate company policies and standards and has implemented detailed procedures for investigating complaints of misconduct or violations of company policies.
Responding promptly to detected problems and undertaking corrective action
Responding promptly to detected problems and undertaking corrective action

Responding promptly to detected problems and undertaking corrective action

Philips utilizes audits and other risk-assessment techniques to monitor compliance, identify high-risk areas and determine corrective action for identified problems.

Philips has policies and procedures in place to address the hiring or retention of individuals or entities excluded from participation in federal health care programs

Annual Certification of Compliance with the Corporate Comprehensive Compliance Program for California

Philips North America LLC, a division of Royal Philips., and its affiliates (“Philips”), has established and is operating under a Comprehensive Compliance Program (“CCP”).

Where applicable, is in accordance with the “Compliance Program Guidance for Pharmaceutical Manufacturers” issued by the United States Department of Health and Human Services Office of Inspector General (“CPG”), and the AdvaMed and NEMA/MITA Codes of Ethics on Interactions with Healthcare Providers (“Device Industry Codes”).

Not a drug manufacturer
Because Philips is a medical device manufacturer – not a drug manufacturer – certain guidance set forth in the CPG does not apply to Philips and its operations. Similarly, Philips’ CCP is based on Device Industry Codes and not the PhRMA Code of Ethics for the pharmaceutical industry.

With these clarifications and Philips’ good faith understanding of the statutory requirements, Philips is – to the best of its knowledge – in compliance with the provisions of the California Health and Safety Code §§119400-119402, to the extent they apply to Philips North America LLC.
[Updated 01-01-2019]

Compliance updates
Please note that our Philips compliance program may vary from country to country to reflect legal differences, and not all programs are available for posting.

California Supplier Transparency Act Disclosure

On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) went into effect in the State of California. As a result, many companies manufacturing or selling products in California are required to disclose their efforts to address the issues of human trafficking and slavery, thereby allowing consumers to make better, more informed choices regarding the products they buy and the companies they choose to support.

Follow this link for Philips policies with respect to this legislation

Always acting with integrity

Contact information

Philips North America LLC Compliance Program

Policies, procedures, and guidance

Designating a compliance officer and compliance committee

Conducting effective training and education

Developing effective lines of communication

Conducting internal monitoring and auditing

Enforcing standards through well-publicized disciplinary guidelines

Responding promptly to detected problems and undertaking corrective action

Annual Certification of Compliance with the Corporate Comprehensive Compliance Program for California

California Supplier Transparency Act Disclosure

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