In performing their duties for Globus Medical, Inc. (“Globus”), every employee shall maintain the highest standards of honest and ethical conduct in all dealings with other employees, customers, suppliers, and other third parties of Globus, including the independent auditors of Globus and any government or regulatory agencies.
It is vital that all employees avoid any actual or perceived conflict of interest between personal and professional relationships. Should any question arise regarding a possible conflict of interest, the employee shall report the transaction or action to their supervisor and the Chief Compliance Officer immediately. Employees will take all reasonable measures to protect the confidentiality of non-public information about the Company.
Any interpretation of the provisions of this Code, as well as interactions with HCPs not enumerated within this Code, should be made with the following principle in mind: Globus requires ethical business practices and socially responsible conduct. Its employees and agents shall not use any unlawful inducement to sell, lease, recommend or arrange for the sale, lease or recommendation of Globus products. Additionally, Globus has adopted the AdvaMed Code of Ethics on Interactions with Health Care Professionals (“AdvaMed Code”) as company policy. Accordingly, Globus requires all employees and agents to fully comply with the provisions set forth in the MedTech Code.
Globus’ accounting records and reports shall be maintained in a fair and accurate manner in accordance with all pertinent laws and with all generally accepted accounting principles. Globus’ Corporate Compliance Program includes efforts to monitor, audit, and evaluate compliance with the company’s compliance policies and procedures, including efforts to monitor the activities of the field sales force. In addition, all employees are required to take all reasonable action to ensure compliance with applicable governmental laws, rules and regulations, both in the United States and internationally.