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

Certification of Compliance

To the best of our knowledge, as of June 30, 2015, Carl Zeiss Meditec, Inc. is in material compliance with its Comprehensive Compliance Program (“CCP”) that satisfies the requirements of California Health and Safety Code Sections 119400 - 119402, based on our good faith understanding of the statutory provisions as they may apply to a medical device manufacturer.

If Carl Zeiss Meditec, Inc. discovers, through audits, its disclosure program, or otherwise, potential or actual violations of provisions of its CCP, it will, where appropriate, investigate the matter and respond promptly consistent with its policies addressing noncompliance or misconduct, as described in the Company’s CCP.

To obtain a print version of this document, please contact Carl Zeiss Meditec, Inc.’s Compliance Toll-Free Number at 1-877-705-4029.

Rev July 2015

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