The purpose of our ethics and compliance program is to prevent and detect violations of law or company policy. Everyone must do their part to honor our 4i Values and maintain our high ethical standards. Colleagues are encouraged to report any issues to their manager, Human Resources or Legal departments or via our Global Ethics Hotline, which is a confidential incident reporting system available to all our stakeholders including customers, suppliers and other external parties.

Learn more about reporting a concern.

We are committed to upholding and respecting human rights for all. Building a brighter future means managing our global operations ethically and with integrity to positively impact the people and communities linked to our business.

Guiding principles

Thermo Fisher is able to support human rights for all people by conducting business with the highest ethical standards and in compliance with applicable laws and Company policy. We are guided by principles set forth in our Human Rights and Equal Opportunity Policy, which was updated in 2022 and establishes our standards for business conduct related to respecting human rights and fair labor practices across our global operation.

This policy helps us implement our commitment to human rights in alignment with leading international standards, including the UN Universal Declaration of Human Rights and the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work. As signatories to the UN Global Compact, we are also committed to aligning our corporate strategy with the Ten Principles on human rights, labor, environment and anti-corruption. When differences arise between our standards and legal requirements, we generally apply the stricter standard in compliance with

applicable laws.

Engaging our stakeholders

Through our human rights management approach, we engage transparently and collaboratively with our stakeholders to drive the effectiveness of our program.

• Colleagues: Our Code of Business Conduct and Ethics outlines the expectations for all directors, officers and colleagues of the Company, including compliance with all internal policies such as those governing human rights. Annual certification of compliance with this code is required and biannual training enhances our colleagues knowledge of human rights within the context of our business and their role in respecting them. Our procurement colleagues receive additional training on the expectations of our supplier responsibility programs, including those related to labor and human rights for our suppliers.

• Suppliers: Our Supplier Code of Conduct shares our compliance expectations for suppliers and their subcontractors in the areas of ethics, labor, health and safety, environment, and management systems. It is integrated into supply agreements and terms and conditions, and suppliers are expected to share their performance against code expectations at the request of Thermo Fisher. Suppliers must have a training program to educate their workforce to address the expectations outlined in this code and are required to participate in Thermo Fisher trainings, as applicable.

• Customers and distribution partners: We provide training, education and resources to help customers, resellers and distributors use our instruments and products as designed and to follow global scientific and ethical standards for the responsible selling, or reselling, of our technologies. Should we be alerted to any ethical question or concern in relation to how customers may be using our technologies, the matter is immediately escalated to our Bioethics Committee.

• Policymakers and influencers: We engage with governments, regulators and non-governmental organizations to contribute to good global policy, such as the responsible application of technology and appropriate security protocols and procedures for safeguarding individual privacy rights. 

Active engagement and feedback from our partners support the continuous improvement of our approach. If, at any time, a stakeholder has a human rights concern, they have the option to contact our Global Ethics Hotline and can submit a report anonymously if desired.

Framework for application of bioethics guiding principles

As the world leader in serving science, Thermo Fisher Scientific has a single Mission: to enable our customers to make the world healthier, cleaner, and safer. To fulfill our Mission, we aspire to hold a clear leadership position for life sciences, healthcare, the environment, and public safety.

As science continues to evolve at an unprecedented pace, it is important that we ethically pursue and uphold our promise to serve as a responsible steward to benefit society. We believe biotechnology not only offers meaningful advancements for science but also bears important responsibilities to companies like ours who develop and employ these tools.

We place the utmost importance on identifying, understanding, assessing, tracking, managing, and overseeing bioethics issues, policies, and practices.

Our bioethics guiding principles

Thermo Fisher’s policies and procedures reflect careful consideration and several guiding principles throughout our product research, development, manufacturing, and sales processes:

• We place the highest priority on the safety and efficacy of our products, and we support government agencies in safeguarding health and well-being throughout the world.
• We recognize that responsible use of biotechnology is consistent with our mission to enable our customers to make the world healthier, cleaner, and safer.
• We carefully and prudently determine the benefits associated with our technologies while seeking to identify and minimize relevant risks.
• We operate in a way that is consistent with global best practices and ethical principles, including, but not limited to, our own companywide Code of Conduct and Ethics Policy, the appropriate local, national, regional, and international governing bodies, and standards found in, but not limited to:
  • Guidelines for Good Laboratory Practices (GLP) and Good Manufacturing Practices (GMP)
  • Declaration of Helsinki International Ethical Guidelines for Biomedical Research Involving Human Subjects 
  • Applicable privacy and data protection standards
• We promote ethical research, safeguard the integrity of the scientific process, and protect patients’ rights while responsibly identifying and addressing issues related to biotechnology research and development.
• We are sensitive to issues surrounding research with animals and humans and advocate for adherence to ethical standards in the research, development, manufacture, and sale of our products.
• We listen to and consider feedback from the public around biotechnology research and development concerns relative to our products and respond with integrity to ethical priorities.
• We actively participate in public discussions and professional forums encouraging science-based policies and regulations that serve the public interest in relation to emerging technologies.
• We contribute to the scientific community by publishing research results and by sharing best practices.

Executive oversight

Board of Directors

As part of our Board of Directors’ oversight of the company, our Science and Technology Committee receives periodic updates on matters involving bioethics and the use of our technologies and products from our Chief Executive Officer, Chief Operating Officer, and our Chief Scientific Officer. These reports include topics such as DNA analysis for human identification and gene editing to advance precision medicine.

The Science and Technology Committee assists the Board in staying abreast of new technologies, markets, and applications of the company’s products. The Committee also monitors and evaluates trends in science and recommends to the Board emerging innovations for strengthening the company’s technological leadership. This Committee meets at least annually, or more frequently as circumstances dictate, and makes periodic reports to the Board.

Senior leadership

Our Chief Executive Officer is responsible for the management of the company, including its bioethics policies and positions. He is supported in the management of these issues by our:

• Chief Operating Officer, who has responsibility for our technology-related businesses
• Chief Scientific Officer, who leads the innovation strategy for the company
• General Counsel, given many bioethics issues also have legal content or implications
• Chief Communications Officer, who develops communications strategies concerning bioethics issues both internally and externally
• And executives who lead businesses that rely on continuous innovation to create a competitive advantage.

Our senior leadership is responsible for:

• Enforcing and embodying our Code of Business Conduct and Ethics
• Approving capital allocation decisions that affect which technologies we pursue and in what markets and customer segments we operate
• Developing and implementing changes in strategic direction brought about by addressing bioethics issues
• Positioning our company as a scientific thought leader globally and ensuring that we remain abreast of trends involving innovative life sciences technologies.

Bioethics committee

Our bioethics framework is monitored and managed by Thermo Fisher’s Bioethics Committee, which is committed to the socially responsible use of biotechnology to save or improve lives.

The Bioethics Committee is a cross-functional team of senior leaders who report regularly to the chairman, president and CEO. Committee members include our executive vice president, chief medical officer, chief scientific officer, and leaders representing our life sciences, clinical research and diagnostics businesses as well as legal and communications functions.

The Committee ensures we satisfy transparent, compliant, and ethical business practices and standards with unyielding integrity throughout our global operations. In particular, the Committee:

• Facilitates a greater understanding and actively encourages discussion of ethical and social implications of scientific developments in biotechnology.
• Defines and articulates Thermo Fisher’s corporate policy and position on current and emerging bioethics topics and issues relevant to R&D to satisfy transparent, ethical business practices.
• Considers feedback from employees, customers, and other key stakeholders on Thermo Fisher’s corporate policies regarding current bioethical issues.
• Facilitates the development, implementation, operation, and improvement of an effective ethics and compliance program.
• Provides guidance to Thermo Fisher’s senior management to interpret aspects of the ethics and compliance program and recommends business strategies and practices that may improve compliance and effectiveness and meet global ethical business standards.
• Advances our company Mission while upholding standards of ethics and integrity in accordance with Thermo Fisher’s bioethics policy.
• Reviews Thermo Fisher’s existing bioethics policies on an ongoing basis, including providing updates to the company’s Science and Technology Committee of its Board of Directors, to ensure they continue to reflect the overall objectives of our customers and our company.

Bioethics policy and specific issue positions

We have a company-wide bioethics policy that is supplemented by internal position statements on individually identified bioethics issues. 

We will strive to:

• Promote bioethical awareness throughout the company
• Operate according to the highest ethical global standards
• Require adherence to high ethical standards by our customers and external partners
• Engage in stakeholder dialogue and partnerships helping us to deal with ethical dilemmas
• Act in accordance with international conventions

Our commitment applies across all Thermo Fisher businesses and in all countries where we do business, and to all work performed at the direction of Thermo Fisher by external organizations, consultants, and third-party vendors.  We apply our policy in accordance with local, national, regional, and international standards, and the principles, regulations, and bodies that govern our areas of technological focus.

Thermo Fisher’s sales practices, product descriptions and marketing practices must always be fair, accurate and consistent with product labeling. Promotional claims must be based on valid scientific evidence and provide accurate, objective and complete information about the product. We must never promote our products for uses that have not been approved by the appropriate regulatory authority, if approval is required.  Thermo Fisher believes in and practices fair trade by not prohibiting our customers or suppliers from dealing with any of our competitors as a condition of obtaining products and services from us, nor do we enter into tying arrangements where a customer is required to purchase one product in order to receive a second distinct product (provided, however, sometimes we do offer a package price for bundled products or services which can also be purchased separately).

The promotion of medical devices and diagnostic products is subject to strict regulation around the world, including by the Food Drug & Cosmetic Act, Anti-Kickback Statute and the Physician Payments Sunshine Act (and similar international regulations). Thermo Fisher employees who are subject to these regulations receive regular trainings on these topics to ensure their understanding with what is required both by the regulations and by the Thermo Fisher Healthcare Code of Conduct (“Healthcare Code”).  Thermo Fisher’s Healthcare Code has been developed in accordance with the AdvaMed Code of Ethics on Interactions with Healthcare Professionals (“AdvaMed Code,” which is based on the Pharmaceutical Research and Manufacturers of America Code on Interactions with Healthcare Professionals, (“PhRMA Code”), the  MedTech Europe Code of Ethical Business Practice (“MTE Code”), and other similar guidance, which takes into account the uniqueness of interactions between medical device manufacturers and healthcare professionals.

The purpose of our compliance program is to prevent and detect violations of law or company policy. Our program consists of written policies and procedures that are overseen by compliance officers within each operating group.  Extensive training and education is provided on an annual basis via both web-based and live training.  Employees are encouraged to report any issues to their Human Resource Department, Legal or via an Ethics Hotline.  Thermo Fisher has adopted policies and procedures to address Healthcare Code violations which can lead to disciplinary action up to and including termination. As the HHS-OIG Guidance recognizes, however, the implementation of such a program cannot guarantee the elimination of improper conduct. It is Thermo Fisher’s expectation that all employees will adhere to our compliance program as well as with all applicable laws, regulations and policies.

Cybersecurity

Thermo Fisher recognizes the importance of maintaining the trust and confidence of our customers and colleagues. To more effectively prevent, detect and respond to information security threats, we have a dedicated Chief Information Security Officer whose team is responsible for leading Company-wide information security strategy, policy, standards, architecture and processes. Additionally, as part of its risk oversight function, the Board oversees our cybersecurity program through the Audit Committee, ensuring we have the policies and processes in place to manage evolving threats. Both the Audit Committee and the full Board receive regular reports from the Chief Information Security Officer and the Chief Information Officer on, among other things, the Company’s cyber risks and threats, the status of projects to strengthen our information security systems, assessments of our security program and the emerging threat landscape.

In 2019, our corporate cybersecurity program earned an ISO 27001 certificate, a globally recognized standard for information security management systems. Additional information on the certification is available here. More information on Thermo Fisher’s data privacy policy is available here.