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2007

ED IT ION

In addition, you acknowledge and agree that you owe a duty to the Company to advance the Company's legitimate interests when the opportunity to do so arises.

Interactions with Healthcare Providers

Kickbacks

A kickback is an act that involves the exchange or an offer to exchange or a solicitation of payments, in any form, directly or indirectly, for the referral or growth of business.

Examples

of payment

any items

of value.

forms are monies, The federal and

fees, state

commissions,

credits,

governments

impose

gifts, gratuities, or criminal and civil

sanctions for to oversee

kickback activities the integrity of

involving healthcare providers. The statute was the healthcare industry including medical

devised device

manufacturing with regard to reimbursement, marketing, and ethical All employees involved in the sale, marketing or advertising the

business conduct. Company and its

products should ensure with Applicable Laws

that and

all products are all information

sold, promoted represented is

and marketed in accordance correct and comprehensive.

Examples of situations the following:

that

could

violate

Applicable

Laws

include,

but

are

not

limited

to

  • Any business ownership arrangement or relationship with a surgeon or his or her agents that involve situations where there is remuneration to the surgeon or his or her family or agents;

  • Services, gifts, non-modest meals or travel arrangements or other perquisites that are offered to a surgeon or his or her family or agents (regardless of whether you seek reimbursement from the Company);

  • Consulting agreements, royalty agreements or honoraria that are used

inappropriately;

Please contact the Compliance Officer with any questions or concerns you may have regarding the application of Applicable Laws to your activities or circumstances.

Venues

All venues or accommodations that are chosen for the purpose of training, meetings, conferences or other educational purposes, should be moderately priced, and should focus on the specific function of the event and the convenience of its location for the attendees. This applies not only to physical lodging and accommodations, but also to the geographical location of the chosen venue. Additionally, it is important to note that all events must be business-oriented and Company employees cannot host events that are not specific to a business function or purpose.

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