Business Code of Conduct


Introduction

Spinal Simplicity is committed to conducting business with strong ethical values and patient well being at the forefront. Our commitment to ethical conduct and compliance are the foundation of Spinal Simplicity’s business practices.

Spinal Simplicity has adopted a Code of Conduct, along with a comprehensive compliance program to facilitate a corporate culture that places the utmost value on ethical, compliant behavior in every aspect of our business. All Spinal Simplicity team members, along with distributors and related parties, are expected to abide by the ethical and legal standards set forth in these policies and programs, as well as abiding by the applicable laws and regulations in every country where we conduct business.

Spinal Simplicity has also adopted and is committed to the principles and practices set forth in the AdvaMed Code of Ethics.

Any questions or concerns regarding Spinal Simplicity’s Compliance Program, including reports of potentially problematic conduct, may be directed to the Company’s Director of Compliance at internalreporting@spinalsimplicity.com or 913-553-4514.

Code of Business Conduct

Spinal Simplicity’s Code of Business Conduct provides an overview of the Company’s compliance program requirements which are based on a commitment to ethical business practices and abiding by applicable laws and regulations.

The principles set forth in the Code of Business Conduct are set forth in furtherance of the Company’s Compliance Program. It is expected that every Spinal Simplicity Employee, Contractor, Distributor, Agent, Member, Manager, Officer, and Director engage in business practices that are ethically sound and legally compliant.

By way of example, Spinal Simplicity identifies prohibited conduct below that is not acceptable and would require reporting through the Company’s Compliance Program Reporting Procedure:

  • Actions that could harm Spinal Simplicity’s reputation as an ethical company
  • Creation of financial records that don’t accurately reflect the financial transaction
  • Avoidance of the Company’s standard review and control processes
  • Failure to properly administer Company record retention practices
  • Failure to appropriately carry out job duties as required by law
  • Funds or transactions that have not been reported and/or accurately recorded
  • Transactions that lack the proper supporting documentation
  • Falsification of any reports
  • Engaging in any unethical act to entice a customer, potential customer, or other third party to do business with the Company
  • Acceptance of kickbacks or similar payments
  • Authorization for payment of goods and services not received, or over payment for goods actually received or valid services performed
  • Misuse of Company resources
  • Unauthorized or improper access, misuse, modification, destruction or disclosure of Company data
  • Theft of Company equipment/resources
  • Using “workarounds” or schemes to avoid complying with domestic and/or international rules and regulations or Company policies
  • Any inappropriate relationship that could create a conflict of interest or potential conflict of interest

Spinal Simplicity’s goal is to set forth the standards for appropriate and ethical business conduct, to monitor compliance with the Company’s Compliance Programs, to respond to reports of unauthorized conduct, and to take actions to address any such conduct and prevent its occurrence in the future.