Ethics

Thermo Fisher Scientific is committed to ethical and lawful behavior and to acting professionally and fairly in all business dealings and relationships.

99% ethics and compliance training completion rate1

Code of Business Conduct and Ethics

Thermo Fisher’s Code of Business Conduct and Ethics (the Code) reflects our 4i Values and sets clear expectations for all colleagues to act with integrity and comply with applicable laws and regulations. The Code addresses a broad range of topics, including ethical decision-making, respectful workplace conduct, conflicts of interest, fair dealing, anti-bribery, insider trading, responsible use of resources (including artificial intelligence), export control awareness, human rights, privacy and accurate recordkeeping. Additional stand-alone policies governing many of these topics help to expand our colleagues’ understanding and clarify expectations.

All directors and colleagues are responsible for certifying annually that they have reviewed and are following the Code. Colleagues can also access training on specific topics within the Code or more detailed guidance on their responsibilities.

The Code and its related trainings are translated and available in 20+ languages for our global team.

Ethical business practices

Thermo Fisher is committed to conducting business with integrity and maintaining a strong control environment designed to prevent and detect bribery and corruption. We use risk assessments to identify potential areas of concern and support our program with clear policies, procedures and trainings that help colleagues understand their responsibilities. In 2025, our annual Compliance Week reinforced awareness by engaging colleagues across a range of topics, including privacy, government contracts, anti-bribery and anti-corruption, healthcare compliance and global trade compliance.

Anti-corruption

Our Global Anti-Corruption Policy provides the foundation for our anti-corruption program and applies to all Thermo Fisher colleagues as well as our business partners. Available in multiple languages, the policy provides a framework for colleagues, reinforcing our prohibition of bribery and corruption in any form. To support effective implementation, we maintain controls and compliance tools for areas such as conflict of interest disclosures, third-party due diligence, and travel and hospitality approvals. We regularly review and enhance these tools using analytics and internal feedback to strengthen both effectiveness and usability.

Our anti-corruption program is also supported by annual training, internal controls and an investigations framework for reviewing and addressing potential violations. Through this approach, we work to uphold ethical business practices across our global operations and comply with applicable anti-corruption laws, including the US Foreign Corrupt Practices Act of 1977 (FCPA) and the UK Bribery Act 2010 (UK Bribery Act).

Our approach to anti-corruption extends beyond our organization. Third-party compliance is a critical aspect of our approach, requiring suppliers and distribution channel partners to adhere to the same 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 value chain.

Human rights

We are committed to upholding and respecting human rights by conducting business 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 to drive awareness, compliance and adherence to governing principles and ethical and legal codes.

Through our human rights due diligence program we conduct risk assessments of our operations and supplier network in compliance with the latest regulatory requirements. In 2025, we expanded our due diligence assessments downstream with targeted questions and compliance certifications on labor and human rights topics for third-party 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 supports 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 across our value chain, including our upstream supplier network and downstream distribution channels. 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 downstream stakeholders, including 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.

More information on our stakeholder engagement is available in our Human Rights and Modern Slavery statement on the CSR reporting hub.

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 2025, we expanded our human rights training programs in response to evolving global regulatory requirements and stakeholder expectations. This included new enterprise-wide training on human rights and modern slavery, alongside role-specific training that provides colleagues with practical guidance relevant to their responsibilities. For example, procurement colleagues receive targeted training aligned with our responsible sourcing program, including labor and human rights considerations for workers across the supply chain. To further support this work, we launched a centralized internal human rights resource site that provides timely updates, practical guidance and access to resources, helping colleagues embed respect for human rights into daily operations.

More information on how we operationalize our approach to human rights is available in the R es ponsible 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

Read about our Bioethics Committee

Healthcare compliance program

Thermo Fisher’s healthcare compliance program reflects our commitment to ethical business practices, responsible interactions with healthcare professionals and healthcare organizations, and compliance with applicable laws, regulations and industry standards. Through training, education and oversight, the program helps our colleagues conduct business with integrity and transparency.

A key component of the program is Thermo Fisher’s Code of Conduct on Interactions with Healthcare Professionals (Healthcare Code of Conduct). Developed in alignment with the AdvaMed™ Code of Ethics on Interactions with Healthcare Professionals, industry guidance and federal, state and regional laws, the Healthcare Code of Conduct provides our teams a comprehensive guide for ethical practices in the healthcare industry.

To reinforce these standards, all colleagues are expected to complete training and education on relevant topics, at a minimum, annually. Thermo Fisher also maintains policies and procedures for addressing potential violations, which may result in disciplinary action up to and including termination.

By adhering to our healthcare compliance program as well as applicable laws, regulations and company policies, our colleagues uphold our responsibility to doing business the right way--advancing our Mission by building trust and credibility across healthcare and patient communities.

Responsible sales and marketing

Thermo Fisher strives to conduct all sales, marketing and product communication practices with integrity, accuracy and transparency. Our policies establish expectations for fair, accurate and transparent sales and marketing practices that are consistent with approved product labeling. Promotional claims are supported by valid scientific evidence and provide complete, objective and accurate information. We do not promote products for uses that have not been approved by the appropriate regulatory authority where such approval is required.

We uphold principles of fair trade and responsible business conduct across our commercial activities. We do not restrict customers or suppliers from engaging with competitors as a condition of doing business with us, nor do we require the purchase of one product to obtain another. While we may offer bundled solutions at a combined price, each product or service remains available for purchase independently.

The promotion of medical devices and diagnostic products is governed by global regulatory frameworks, including the US Food, Drug, and Cosmetic Act, the Anti-Kickback Statute and the Physician Payments Sunshine Act, as well as comparable international regulations. To help colleagues meet these requirements, we provide regular, role-specific training tailored to their responsibilities, reinforcing accountability and ethical practices.

Endnote:

This indicator is calculated based on the number of ethics and compliance courses completed out of the number of ethics and compliance courses assigned to all colleagues.

Last updated: July 2026

About Thermo Fisher Scientific

Thermo Fisher Scientific Inc. (NYSE: TMO) is the world leader in serving science, with annual revenue over $40 billion. Our Mission is to enable our customers to make the world healthier, cleaner and safer. Whether our customers are accelerating life sciences research, solving complex analytical challenges, increasing productivity in their laboratories, improving patient health through diagnostics or the development and manufacture of life-changing therapies, we are here to support them. Our global team delivers an unrivaled combination of innovative technologies, purchasing convenience and pharmaceutical services through our industry-leading brands, including Thermo Scientific, Applied Biosystems, Invitrogen, Fisher Scientific, Unity Lab Services, Patheon and PPD.

For more information, please visit www.thermofisher.com