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2007

ED IT ION

Meals

The Company will provide reimbursement for meals, provided that the meal is moderate in price and it is for the purpose of exchanging information concerning business products, services, or education. In addition, all reimbursement for meals shall be subject to the Company's travel and expense reimbursement policy. It is unacceptable to violate this policy regardless of whether or not you seek reimbursement from the Company.

Travel

All reimbursement for surgeon travel must be modest (i.e. coach–class airfare). It is unacceptable to violate this policy regardless of whether or not you seek reimbursement from the Company.

Gifts

No gifts should be given by Company employees to surgeons, except for nominal gifts that benefit the surgeon's patients, such as pads, pens or the like. Pursuant to Applicable Laws there are stringent requirements applicable to giving a surgeon a gift.

Using caution at all times is demanded by the Company regarding business conduct that concerns gift giving.

Inappropriate receiving or giving of gifts could include, but is not limited to:

  • any gift that only benefits the surgeon and does not have any patient benefit, such as wine, cigars, gift baskets, holiday gifts, golf outings, concerts, books unrelated to the surgeon's medical practice, artwork, etc.;

  • any gift that is not in compliance with Applicable Laws; or

  • gifts of cash or a cash equivalent, including gift certificates, loans, investments,

checks or any other form of cash or other cash equivalents.

If you have any questions about giving gifts, please consult with the Compliance Officer. It is unacceptable to violate this policy regardless of whether or not you seek reimbursement from the Company.

AdvaMed

The Company has adopted the AdvaMed Code of Ethics on Interactions with Healthcare

Professionals.

The

AdvaMed

Code

helps

to

provide

insight

and

Company's expectations regarding business conduct with surgeons. questions regarding the AdvaMed Code, please contact the Compliance

guidance on If you have Officer.

the any

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