1. COMPREHENSIVE COMPLIANCE PROGRAM
Carl Zeiss Vision Inc. is committed to conducting business with uncompromising integrity and the highest levels of business ethics. In service of this mission, Carl Zeiss Vision conducts activities in compliance with applicable laws, regulations, and industry codes. We commit to acting honestly, ethically, and fairly, and work to ensure that our conduct, and that of our third-party business partners, meets and exceeds all required standards.

We also declare that the structure of our Comprehensive Compliance Program (CCP) and based on our good faith understanding of the law, 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 CCP adopted by Carl Zeiss Vision is intended to adhere to the "Code of Ethics on Interactions with Healthcare Professionals" issued by the Advanced Medical Technology Association (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.
Carl Zeiss Vision’s CCP is designed to prevent non-compliance with company policies and the laws and regulations and effectively detect and correct non-compliance. Carl Zeiss Vision’s CCP is flexible and evolving, incorporating periodic risk assessments and adjustments to policies and practices to ensure the program can address the changing needs and emerging compliance risks of our business.

1.1 Implementing Written Policies and Procedures
As part of Carl Zeiss Vision’s CCP, Carl Zeiss Vision has established a Code of Conduct. All employees interacting with Healthcare Professionals (HCPs) and other customers are required to follow additional policies and procedures governing appropriate and inappropriate actions. Carl Zeiss Vision updates these policies and procedures on an ongoing basis and ensures they are available and provided to all employees and relevant third parties.

1.2 Designating a Compliance Officer and Compliance Committee
Carl Zeiss Vision has designated a Compliance Officer charged with operating and monitoring Carl Zeiss Vision’s CCP. Additionally, the Compliance Officer has the authority to report on its CCP directly to the Board of Directors.

1.3 Conducting Regular, Effective Training and Education
Carl Zeiss Vision requires periodic compliance training for all personnel on the policies and procedures established as part of the CCP.

1.4 Developing Effective Lines of Communication
Carl Zeiss Vision has established an open line of communication for employees to contact the Legal and Compliance Department and report compliance questions and concerns to management and the Board of Directors. Personnel have a mechanism to report questions and concerns anonymously.

1.5 Conducting Internal Monitoring and Auditing
Carl Zeiss Vision reviews and assesses business activities for compliance with applicable laws, regulations, guidelines, and company policies and procedures. This includes evaluating and identifying potential risks on an ongoing basis. Once potential risks are analyzed, the company identifies how to address any high-priority item, including by conducting an audit or putting monitoring in place.

1.6 Enforcing Standards Through Well-Publicized Disciplinary Guidelines and Incentivizing Compliance
Carl Zeiss Vision reviews and assesses business activities for compliance with applicable laws, regulations, guidelines, and company policies and procedures. This includes evaluating and identifying potential risks on an ongoing basis. Once potential risks are analyzed, the company identifies how to address any high-priority item, including by conducting an audit or putting monitoring in place.

1.7 Responding Promptly to Detected Problems and Undertaking Corrective Action
Carl Zeiss Vision develops corrective action plans to address identified concerns in a timely fashion. Appropriate corrective action may include disciplinary action, enhanced training, improvement of policies and procedures, or reporting obligations to governmental authorities.
It is Carl Zeiss Vision’s expectation that all employees and contractors comply with its CCP and all policies that support this program. As part of Carl Zeiss Vision’s continuing commitment to compliance, Carl Zeiss Vision continually reviews and revises the elements of its CCP.
To obtain a written copy of Carl Zeiss Vision’s Code of Business Conduct and Ethics and written Declaration of Compliance, contact us at 888-208-2022.

2. DECLARATION OF COMPLIANCE
Carl Zeiss Vision declares that, to the best of our knowledge, and based on our good faith understanding of the statutory requirements of the California Health & Safety Code §§ 119400-119402, we are in compliance with our Comprehensive Compliance Program (CCP) for the prior calendar year.