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2007

ED IT ION

Purpose of the Code of Conduct

Alphatec Spine, Inc., and its parent company, Alphatec Holdings, Inc. (collectively, the “Company”) requires legal and ethical behavior from all of its employees at all times. The Company has developed this Code of Conduct to provide you with guidance as to the necessary business conduct and principles that, if not followed by each and every Company employee, could have a negative effect on our business success. This Code of Conduct is part of a larger process that includes compliance with the Company’s corporate policies and procedures, an open working relationship between management and all employees, and your integrity and proper judgment.

In this regard you must always:

  • comply with all applicable laws, rules, regulations and guidelines;

  • ensure that all dealings with the Company’s surgeons or other healthcare providers (hereinafter, each a "surgeon" and collectively the "surgeons"), customers, suppliers and competitors is conducted fairly;

  • ensure that all conflicts of interest are handled in accordance with this Code of Conduct;

  • refrain from using your position in the Company or the Company’s assets or information for improper personal gain;

  • take all actions necessary to ensure that the Company produces fair, accurate, timely and coherent disclosure in all reports and documents that the Company files with the Securities and Exchange Commission, and in its communications to the public;

  • properly use and prevent the improper disclosure of the Company’s proprietary information; and

  • protect the Company’s assets and immediately report any suspected theft

or fraud involving the Company’s assets.

Violations of this Code of Conduct will subject you to disciplinary action, up to and including immediate termination of your employment. You must report all violations of the Code of Conduct to your immediate supervisor or to the General Counsel and Vice President, Compliance (the “Compliance Officer”) or the Vice President, Human Resources. In addition, you can use the Compliance Telephone Hotline or the Internet Compliance Hotline (instructions for using both of these hotlines are posted in common areas in the Company's facilities and such

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