Compliance

Ethics & Compliance

Carl Zeiss Meditec, Inc. is committed to upholding the highest ethical standards in its management practices. These standards are driven by the principles of the Carl Zeiss (CZ) group and the requirements of US federal and state regulations. This policy references the CZ Code of Conduct, AdvaMed Code of Ethics and the US Federal Foreign Corrupt Practices Act (FCPA) as the basis for acceptable behaviors and defines additional specific policies in order to meet compliance requirements of federal or state laws when they are more stringent than the AdvaMed Code of Ethics.

CZ Code of Conduct
US Federal Foreign Corrupt Practices ACT (FCPA)

Employee Code of Conduct

At Carl Zeiss Meditec, Inc., management and employees are expected to adhere to the CZMI Code of Conduct and the Code of Conduct for the Carl Zeiss Group, in addition to complying with the laws and regulations of the United States Federal Government, individual states, and other countries where Carl Zeiss Meditec, Inc. conducts business.

 

Interaction with Health Care Professionals

Carl Zeiss Meditec, Inc. has adopted a Compliance Policy for interactions with health care professionals which is based on the Advanced Medical Technology Association Code of Ethics on Interactions with Health Care Professionals (the “AdvaMed Code of Ethics”; effective July 1, 2009), and which regulates the Company’s interactions with health care professionals. Carl Zeiss Meditec, Inc. has supplemented the AdvaMed Code with certain provisions necessary to comply with state laws governing these interactions as appropriate.

AdvaMed Code of Ethics

Declaration Pursuant to California Health and Safety Code §119402(e) – January 2019

Carl Zeiss Meditec, Inc. is committed to conducting business with uncompromising integrity and the highest levels of business ethics. Carl Zeiss Meditec has established a Comprehensive Compliance Program (“CCP”) in accordance with the Compliance Program Guidance published by the Office of Inspector General, U.S. Department of Health and Human Services (“HHS-OIG Guidance”).

To the best of our knowledge and believe, and based on our good faith understanding of the law, our CCP meets the requirements of California Health and Safety Code §§119400 – 119402. Consistent with the HHS-OIG Guidance, we have tailored our CCP to the size, organizational structure, resources and nature of our medical device business. The medical device industry has established, and Carl Zeiss Meditec’s CCP is designed in accordance with, a voluntary ethical code called the AdvaMed Code of Ethics on Interactions with Health Care Professionals (AdvaMed Code). The AdvaMed Code is substantially equivalent to the Pharmaceutical Research and Manufacturers of America Code on Interactions with Health Care Professionals (PhRMA Code), but reflects the unique interactions between medical technology companies and health care professionals.

Government standards on compliance recognize that even an effective CCP may not completely eliminate improper conduct by individual employees. It is Carl Zeiss Meditec’s expectation that all employees will comply with our CCP as well as with all applicable laws, regulations, and policies. Recognizing that compliance is a dynamic concept, Carl Zeiss Meditec continually reviews, assess, and improves our CCP to meet changing needs and circumstances.

As noted in the Compliance and Ethics Program description, it is possible, and likely, that we will update our Program on an ongoing basis. Copies of this Declaration and the Compliance and Ethics Program description may be obtained by calling Carl Zeiss Meditec, Inc.’s Compliance Toll-Free Number at 1-877-705-4029.