Supply Chain Ethical Code


At every turn, Truven Health Analytics endeavors to do the right thing, conducting our business honestly and with good judgment while complying with the many different laws, rules and standards of conduct that apply to us in the countries where we do business. We are also committed to developing strong business relationships with high quality Suppliers that have committed to operate under ethical standards equivalent to our own.

Truven Health Analytics ethical values and our resulting approach to the way we do business are reflected in the Truven Health Analytics Code of Business Conduct and Ethics. Our Supply Chain Ethical Code applies to our Suppliers worldwide and seeks to encourage comparable standards of behavior, driving commitment to ethical improvements through our supply chain.


As a Truven Health Analytics Supplier, you are required to comply with the provisions of the Truven Health Analytics Supply Chain Ethical Code as set forth below.


In this Code:

Supplier” means a company, partnership or individual that is supplying goods or services to one or more members of the Truven Health Analytics group of companies.

Worker” means any individual whom the Supplier employs, hires, engages or otherwise uses to conduct its business.


The terms of the Code apply equally (i) to any affiliated company of the Supplier and (ii) to any agent or sub-contractor of the Supplier to the extent that such agent or sub-contractor is performing services for the Supplier or its affiliated company. Accordingly, the term “Worker” may also include any individual employed, hired or otherwise engaged by the Supplier’s affiliated companies or by the Supplier’s or its affiliates companies’ sub-contractors or agents.


1. Employment is chosen freely

1.1. Workers work voluntarily and are neither forced nor bonded to work nor work in an involuntary capacity in prison labor.

1.2. Workers are not required to lodge "deposits" or their identity papers with their Supplier and are free to leave their Supplier after reasonable notice.

2. Freedom of association and the right to collective bargaining are respected

2.1. Workers have the right to join or form trade unions of their own choosing and to bargain collectively.

2.2. Suppliers comply with all applicable legislation regarding the activities of trade unions and their organizational activities.

2.3. Workers’ representatives are not discriminated against and are free to carry out their representative functions in the workplace.

2.4. Where the rights to freedom of association and collective bargaining are restricted under law, the Supplier will not restrict the development of other legal means for independent and free association and bargaining.

3. Working conditions are safe and hygienic

3.1. Workers will be provided with a safe and hygienic working environment, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps will be taken to prevent accidents and injury to Workers arising out of, associated with, or occurring in the course of work carried out by the Workers, by minimizing, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

3.2. Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned Workers.

3.3 Workers will be provided with access to clean toilet facilities and drinkable water, and, if appropriate, sanitary facilities for food storage shall be provided.

                3.4. Living accommodation, where provided, shall be clean, safe, and meet the basic needs of the Workers.

3.5. Suppliers will assign responsibility for health and safety to a senior management representative.

4. Child labor shall not be used

                4.1. All Workers will be aged 16 or over.   

                4.2. Workers aged 18 or under will not be employed at night or in hazardous conditions.

5. Living wages are paid

5.1. Wages and benefits paid to Workers for a standard working week meet the higher of the applicable national legal standard (if any) or the amount required to meet basic needs and to provide some discretionary income.

5.2. All Workers will be provided with written and understandable information about their wages and benefits before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid.

5.3. Deductions from wages as a disciplinary measure shall not be permitted, nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the Worker concerned. All disciplinary measures shall be recorded.

6. Working hours are not excessive

6.1. Working hours comply with national laws and industry benchmark standards, whichever affords greater protection to the Worker.

7. No discrimination is practiced

7.1. There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

8. Regular employment is provided

8.1. To every extent possible, work performed must be done so on the basis of a recognized employment relationship established in accordance with national law and practice.

8.2. Obligations to Workers under labor or social security laws and regulations shall not be avoided through the use of labor-only contracting, sub-contracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.

9. No harsh or inhumane treatment is allowed

9.1. Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be strictly prohibited.

10. Anti-bribery and Corruption

10.1. Supplier will comply with the US Foreign Corrupt Practices Act (“FCPA”), as well as with the relevant anti-corruption and anti-bribery laws of the countries in which it conducts business with Truven Health Analytics.

11. Supplier Diversity

11.1. Supplier will, on request, provide Truven Health Analytics with evidence that they have implemented or are working toward implementing a supplier diversity program and/or supplier diversity policy. In the absence of such evidence, Supplier will provide a statement describing their current position regarding supplier diversity.

12. The Environment

12.1. Supplier will, on request, provide Truven Health Analytics with evidence that they have implemented or are working toward implementing an environmental program and/or environmental policy. In the absence of such evidence, Supplier will provide a statement describing their current position regarding the environment.