California Compliance

Code of Conduct

Dornier MedTech

Dornier has created its Comprehensive Compliance Program (“CCP”) to meet the nature of its business as a medical device manufacturer. While California Health and Safety Code §§ 119400-119402 makes reference to compliance with the Pharmaceutical Research and Manufacturers of America’s Code on Interactions with Healthcare Professionals (“PhRMA Code”), Dornier manufactures medical devices rather than pharmaceutical products. Therefore, Dornier determined that it was more appropriate for the company instead to adopt policies and procedures consistent with the AdvaMed Code of Ethics on interactions with Healthcare Professionals (“AdvaMed Code”) which, although substantially similar to the PhRMA Code, recognizes significant differences applicable to the medical device industry.
Dornier is committed to the highest standards of ethical and legal conduct. We have developed a CCP that is reasonably designed to prevent and detect violations, and includes the following:

• Written Standards: We have established and implemented a Code of Conduct and Ethics as well as a Compliance Policy that is consistent with the provisions of the AdvaMed Code.
• Leadership and Structure: We have established effective oversight over the CCP, including selection of a Compliance Officer to develop, operate, and monitor the CCP and creation of a compliance committee to provide strategic direction and oversight.
• Training and Education: All employees received copies of our Code of Conduct and Ethics and Compliance Policy and certify that they have read, understood, and agree to abide by these written standards. We also provide ongoing comprehensive live training to those employees who regularly interact with healthcare professionals.
• Lines of Communication: To facilitate an open door environment, we have adopted confidentiality and non-retaliation policies as well as mechanisms to facilitate anonymous reporting.
• Auditing and Monitoring: Our CCP includes ongoing efforts to monitor, audit, and assess compliance.
• Enforcement: Dornier will consistently investigate and appropriately respond to violations.
• Corrective Action: Dornier will take appropriate corrective action to prevent violations from recurring, including repairing any gaps in our policies or procedures.

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Argelsrieder Feld 7, D-82234 Weßling, Postfach 1251, D-82231 Weßling
Sitz der Gesellschaft: Weßling, Amtsgericht München, HRB 113816, Ust-Id Nr. DE 183642248, Steuer-Nr. 117/115/20564
Vorsitzender des Aufsichfsrats: Prof. Tan Ser Kiat
Geschäftsführung: Abel Boon Thong Ang | Ng Siok Eng Catherine