Ethical Business Conduct

At Intuitive, we believe that every employee is responsible for safeguarding our company’s reputation by acting ethically and with integrity. An ethical culture starts with our leadership expectations. One of those expectations is to lead by example, and we strive to achieve that each day.

We engage and educate employees on ethics in several ways, including through our Code of Business Conduct and Ethics, annual review process, employee training, and communications. We have a formal disclosure document that outlines the requirements and processes we have developed and use to maintain the highest standards of business conduct when interacting with healthcare professionals. See our Ethical Marketing Disclosure.

In addition, our Code of Business Conduct and Ethics is available in the following languages:

On October 30, 2025, the Board of Directors of Intuitive Surgical, Inc. approved an amended Code of Business Conduct and Ethics (the “Code”). The Code was updated to, among other things, (i) improve readability and organization of the Code, (ii) clarify and augment the existing Code’s provisions regarding compliance with applicable governmental laws, rules and regulations as well as company policies and procedures, and (iii) add new discussion on topics relating to positive patient outcomes, working with healthcare providers, product promotion, working with third parties, data privacy and protection, respecting human rights, and our responsibility to the environment and our community. Please refer to the full text of the Code for additional details.

Anti-bribery, anti-corruption, training, and transparency

We abide by applicable anti-bribery laws that exist in the countries in which we operate. This position is also reflected in our policies and contracts with distributors and suppliers, where we require our employees, distributors, and suppliers to comply with applicable anti-bribery and anti-corruption laws and regulations. See our Supplier Code of Conduct.

To address compliance concerns, we use the Intuitive ComplianceLine as a secure and anonymous channel for all employees, contingent workers, customers, third-party agencies, and others to anonymously report suspected violations. Throughout each year, we issue periodic reminders to employees of their obligation to raise concerns related to ethics and compliance via the ComplianceLine and other channels.

Compliance training

Our compliance training and policies on anti-bribery, anti-corruption, and ethical business conduct are regularly reviewed and updated. Training on our code of conduct and business ethics policy is available in seven languages: French, German, Spanish, Korean, Japanese, Chinese, and English to facilitate understanding throughout our global workforce. The training covers our expectations and requirements regarding inclusion and diversity, anti-bribery and anti-corruption, harassment and discrimination prevention, and safeguarding data and data privacy.

Our compliance training was completed by more than 99% of our employees within 60 days of assignment in 2022. We require all global employees to complete this important training at the time of hire, annually, or as local regulations require, and each employee must demonstrate knowledge and awareness through an end-of-course assessment.

Internal controls

To help monitor compliance by the third parties with whom we conduct
business, we perform periodic audits for compliance with anti-bribery and anti-corruption laws. Moreover, we continually refine our internal controls, including strengthening training and certification requirements of third parties with whom we work.

Tax transparency

We are committed to supporting strong corporate governance and financial transparency. Our commitment to tax transparency is embodied in our Global Tax Policy Statement.