Compliance and Integrity

The strength and reputation of McKesson is based on our commitment to the highest standards of business conduct in our relationships with each other and with our customers, suppliers, and shareholders. Our commitment to lead the healthcare evolution, by delivering the best products, services and business solutions to our customers is built on the foundation of our ICARE values. Our Code of Business Conduct and Ethics provides each of us with the guidance to make appropriate decisions when we are faced with ethical issues or policy-based questions.
In addition to the Code of Business Conduct and Ethics, McKesson has implemented several additional policies and tools that set the standards of how we conduct business around areas including but not limited to healthcare fraud and abuse, Foreign Corrupt Practices Act (FCPA), charitable giving and responding to allegations of wrongdoing.
These policies and tools help us drive responsible practices in our interactions with business partners, healthcare professionals, government officials and other customers as well as driving continuous improvement of the ethical culture at McKesson.

Comprehensive Compliance Program

McKesson has established a comprehensive compliance program that is based on the standards and guidelines set out by the Office of the Inspector General (OIG) of the U.S. Department of Health and Human Services. Our compliance program includes maintaining the company's written compliance policies and procedures; reporting to management on compliance matters and program effectiveness; administering a compliance training program; coordinating internal compliance monitoring activities; reviewing complaints, reports and questions received through McKesson's toll-free Ethics Line and other internal lines of communication; coordinating investigations relating to compliance matters; and, where necessary, ensuring that corrective action is taken.
A comprehensive compliance training program that combines both interactive on-line training and in-person training programs helps ensure that our employees are familiar with our Code of Business Conduct and Ethics and company policies. Topics covered by this training program include the Code of Business Conduct and Ethics, fraud and abuse laws, sexual harassment, HIPAA and patient privacy, international anti-bribery, antitrust and trade regulation laws and other ethics and compliance risks.

EthicsLine

The McKesson EthicsLine, available 24-hours a day, 7 days a week, allows employees to report violations (anonymously if they wish) of McKesson policies or other suspected illegal or unethical activity. Calls are answered by an independent third-party provider who documents all calls received before forwarding them to McKesson. All allegations are investigated and, on a periodic basis, a comprehensive report of allegations and investigations is provided to senior management and the Board of Directors.
In addition to the EthicsLine, employees are encouraged to contact the Global Compliance department, their business unit compliance contact, the Legal department, or their supervisors with any questions or concerns they may have regarding our compliance program, any company policies and procedures, or the proper course of action in a particular situation. The Global Compliance and Ethics department maintains both a separate phone line and e-mail address, integrity@mckesson.com, for this purpose. Retaliation against an employee who makes a complaint through the EthicsLine or other channels, or who cooperates in an investigation is not tolerated at McKesson.
Regardless of whether they are detected through the EthicsLine or other lines of internal communication or through monitoring and audits, compliance concerns are promptly investigated. Disciplinary action, re-training, revision of policies and procedures, or other corrective actions are taken as warranted by the situation. Ultimately, it is every employee's responsibility to assure that we as a company comply with the many laws, regulations and ethical standards affecting our business.

Our Anti-corruption Policies

Despite being headquartered in the United States, our business is an increasingly global one. We recognize the importance of demonstrating strong ethics and corporate citizenship in the global economy. We want to make it clear that our ICARE principles do not stop at the border and we recognize the importance of demonstrating strong ethics and corporate citizenship in the global economy. Employees who work in the international arena also need to be familiar with very strict laws prohibiting commercial, governmental and public entity corruption.

McKesson has always prohibited bribery and other forms of corruption in our business and continues to refine and enhance its programs. In Fiscal Year 2010, we adopted a new Global Anti-Corruption Policy and Compliance Manual and we are deploying targeted training.

Corporate Governance and Our Board of Directors

McKesson is committed to, and for many years has adhered to, sound and effective corporate governance practices. Our board of directors is committed to diligently exercising its oversight responsibilities of the company's business and affairs consistent with the highest principles of business ethics and meeting the corporate governance requirements of both federal law and the New York Stock Exchange.

Detailed information about our corporate governance practices, including bylaws and directors' biographies is available on our corporate website.

Corporate Citizenship Governance and Structure

At McKesson, several departments collectively govern our Corporate Citizenship strategy, as described by the diagram below:

individuals within business units, several other structures help to manage our citizenship efforts and initiatives. They are as follows:

The Compliance Operating Committee: A cross-functional group of employees that meets to implement enterprise-wide compliance and ethics policies, protocols and risk assessments.

The Charitable Contributions Compliance Committee: Led by McKesson's Vice President, Corporate Citizenship, this cross-functional group of executives ensures that all charitable contributions made through any of McKessson's business units are aligned and in compliance with the company policy.

Regional Volunteer Coordinators: 218 employees across 136 McKesson locations volunteer to organize community involvement projects and events at their locations, including our annual Community Days projects.

Diversity Councils and Site Action Teams: Responsible for fostering a culture of diversity and inclusion at our facilities, McKesson has two Diversity Councils and seven Diversity Site Action Teams across the U.S.

McKesson's Environmental Councils: Launched in 2006, McKesson's Environmental Councils are groups of employees who are responsible for environmental sustainability initiatives at the local facility level. The councils developed a formal mission and governance structure in July 2009, and at the end of FY09 Environmental Councils had formed in 12 locations.