Ethics 

99% Ethics and compliance training completion rate*

Code of Business Conduct and Ethics 

Our values are represented in the Thermo Fisher Code of Business Conduct and Ethics (the Code), which defines our expectations for all colleagues to adhere to these practices and comply with all applicable laws and regulations. Our Code covers a broad range of topics, including policies related to ethical decision-making, working together respectfully, conflicts of interest, honest and ethical fair dealing, bribery and improper payments, insider trading, responsible use of resources, export control awareness, human rights, privacy matters and accuracy of records. 

Stand-alone policies governing these critical topics help to expand our colleagues’ understanding, set expectations and provide more detailed guidance on topics such as anti-corruption and anti-money laundering, antitrust, banking, environmental health and safety, human rights and equal employment opportunity, export/import controls, responsible artificial intelligence, global data privacy and records management. 

All directors and colleagues are responsible for certifying annually that they have reviewed and are following the Code. Additionally, all colleagues participate in annual training on specific Code elements to understand how they apply to their role.  

The Code and its related trainings are translated and available in 21 languages for our global team, including all colleagues and contingent workers. 

Our Code of Business Conduct and Ethics is supplemented by position statements on individually identified business ethics issues: 

• Animal Testing and Stem Cells 
• HID Technologies 

Ethical business practices 

Thermo Fisher has designed and implemented an internal control environment to prevent and detect bribery and corruption. Risk assessments help identify potential areas of concern, and policies, procedures and training programs are in place to raise awareness among colleagues. In 2024, our annual Compliance Week program covered a wide range of topics, including privacy, government contracts, anti-bribery and anti-corruption, healthcare and global trade compliance. 


Anti-corruption 

To protect our reputation and right to operate in jurisdictions around the world, our Global Anti-Corruption Policy frames our anti-corruption program and applies to everyone at Thermo Fisher as well as our business partners. It is available in multiple languages and provides a framework for colleagues, promoting effective compliance with these laws and emphasizing the prohibition of bribery and corruption in any form. We design, implement and operate stringent controls to prevent and detect bribery, mirroring the commitment observed in various legal frameworks. The effectiveness of our company compliance programs, including annual training, internal controls and an investigations framework for evaluating and remediating potential violations, aligns with the growing emphasis on preventing improper payments. Additionally, Thermo Fisher complies with the US Foreign Corrupt Practices Act of 1977 (FCPA), as amended, the UK Bribery Act 2010 (UK Bribery Act) and all applicable anti-corruption laws, both domestically and internationally.   

Partner expectations 

Our commitment to anti-corruption extends beyond our organization. Third-party compliance is a critical aspect of our approach that requires suppliers and distribution channel partners to adhere to the same rigorous anti-corruption standards we uphold internally. Our due diligence processes play a vital role in identifying and managing potential corruption risks, thus fostering a culture of ethical business practices throughout our supply chain. 

Human rights 

We are committed to upholding and respecting human rights by conducting business to the highest ethical standards and in compliance with applicable laws and company policy. Thermo Fisher’s Global Human Rights Counsel is responsible for leading the coordination of our human rights program across all businesses. This includes expanding training offerings, which will further improve awareness, compliance and adherence to governing principles and ethical and legal codes. 

As a part of our continued commitment to enhance our human rights due diligence practices, we conduct in-depth human rights risk assessments of our operations and supplier network in compliance with the latest regulatory requirements. In 2024, we expanded our third-party due diligence assessments to include targeted questions on labor and human rights topics for our distributors. With the oversight of leadership committees embedded in our enterprise CSR governance model, our process enables regular monitoring and increased reporting capacity to meet the disclosure requirements of country-specific modern slavery, human rights and supply chain due diligence acts in jurisdictions where we operate.  

Our supplier expectations and due diligence program are detailed in the Responsible sourcing section. 

Guiding principles 

We are guided by the principles set forth in our Human Rights and Equal Opportunity Policy, which establishes our standards for business conduct related to respecting human rights and fair labor practices across our global operation. This policy helps us implement a human rights framework aligned 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. Our approach references the United Nations Guiding Principles on Business and Human Rights (UNGP) and the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises. 
  
In line with our human rights framework, we seek to identify and assess adverse human rights impacts that may be linked to our operations, products, services or business relationships. As informed by the implementation guidance from the OECD Due Diligence Guidance for Responsible Business Conduct, we strive to prevent, mitigate, provide remediation for, and track the progress of identified impacts.

Engaging our stakeholders 

We engage transparently and collaboratively with our stakeholders to help ensure the effectiveness of our human rights program. Our Code of Business Conduct and Ethics outlines the requirements for all directors and colleagues within the company, and our Supplier Code of Conduct defines our compliance expectations for suppliers and their subcontractors. For customers, resellers and distributors, we provide training, education and resources to help them use our instruments and products as designed and to follow global scientific and ethical standards for the responsible selling or reselling of our technologies. We monitor best practices through external engagement with human rights peer networks.  
  
We also engage with governments, regulators and nongovernmental 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 supports 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. 

Compliance and accountability 

With the rapid evolution of technology, society’s needs and stakeholder expectations, we continue to strengthen our policies and business processes for identifying, assessing and managing human rights risks, including through periodic internal reviews of our systems and controls. The company policies that touch on our ethical and human rights principles, standards and practices are provided in up to 15 languages.  
  
In 2024, we initiated the expansion of our human rights trainings in line with increasing regulatory requirements and expectations globally. With tailored offerings, we better equip our colleagues with the knowledge and skills required to uphold our human rights commitments in the regions where we operate. For example, procurement colleagues receive training specific to the expectations of our responsible sourcing program, including labor and human rights for workers in the supply chain.  

More information on how we operationalize our commitment to human rights is available in the Responsible sourcing section. 

Bioethics 

As science advances at an unprecedented pace, we continually focus on the ethical and social issues that relate to our role in biotechnology and biomedical research. We value the importance of identifying, assessing, tracking, managing and overseeing bioethics matters, policies and practices. 

Our procedures reflect careful consideration throughout our research, development, manufacturing, sales and distribution processes to prioritize the safety and efficacy of our products. We strive to operate in a way that is consistent with global best practices and ethical principles, including through: 

• Our Code of Business Conduct and Ethics 
• Appropriate local, national, regional and international governing bodies 
• Standards found in guidelines for Good Laboratory Practices (GLP), the Belmont Report for Ethical Principles and Guidelines for the Protection of Human Subjects, Helsinki International Ethical Guidelines for Biomedical Research Involving Human Subjects and applicable privacy and data protection standards 

Bioethics Committee 

Our bioethics framework is monitored and managed by the Thermo Fisher Bioethics Committee, which is comprised of senior leaders who report regularly to our chairman, president and CEO. 
 
Dedicated to the socially responsible use of biotechnology to improve and save lives, the Bioethics Committee works to ensure we satisfy transparent, compliant and ethical business practices and standards with unyielding integrity throughout our value chain. The committee defines, articulates and regularly reviews our corporate policies and positions on current and emerging bioethics topics, considers feedback from our stakeholders and key opinion leaders in the scientific community, and provides updates to the Science and Technology Committee of the Board. 
  
If we receive an ethical question or concern regarding how customers may be using our technologies, the Bioethics Committee is immediately engaged. Following an investigation, the committee determines the course of action in accordance with our values, codes and policies. Examples of past remedial actions have included ceasing the sale of a product to certain customers, engaging with law enforcement and regulatory authorities and implementing enhanced safeguards and controls. 

Healthcare Code of Conduct 

Thermo Fisher’s Code of Conduct on Interactions with Healthcare Professionals (Healthcare Code of Conduct) serves as a comprehensive guide for ethical practices in the healthcare industry. Developed in alignment with the AdvaMed™ Code of Ethics on Interactions with Healthcare Professionals, along with other industry guidance and federal, state and regional laws, the Healthcare Code of Conduct helps ensure that our colleagues adhere to the highest standards of integrity and transparency. Our colleagues receive training and education annually, at a minimum, on relevant topics to remain compliant. 

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 US Department of Health and Human Services (HHS) Office of Inspector General (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. 

Responsible sales and marketing 

As the world leader in serving science, Thermo Fisher Scientific recognizes that it plays an important role in the life sciences, healthcare, the environment, and public safety.  Accordingly, it is committed to complying with federal policies and guidance related to the products and services we offer.

For example, in April 2024, the White House Office of Science and Technology Policy (OSTP) published its Framework for Nucleic Acid Synthesis Screening, which requires nucleic acid synthesis providers to implement biosecurity and information security measures, including the following: 

• Retaining records relating to orders for synthetic nucleic acids. 
• Screening orders for synthetic nucleic acids to identify sequences of concern (SOCs). 
• Verifying with customers the need for synthetic nucleic acids with SOCs. 
• Reporting potentially illegitimate purchase orders of synthetic nucleic acids involving SOCs to the relevant authorities. 

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.

For additional information on ethics and compliance including trainings and our Healthcare Code of Conduct please see above sections.