In performing their duties for Globus, each employee will maintain the highest standards of honest and ethical conduct in all dealings with other employees, customers, suppliers, and other third parties of the Company, including the independent auditors of Globus and any government or regulatory agencies.  All employees will avoid any actual or perceived conflict of interest between personal and professional relationships. When there is any question about the possibility of a potential conflict of interest, the employee will report the transaction or action immediately to the Board of Directors of the Company.  Employees will take all reasonable measures to protect the confidentiality of non-public information about the Company.

The Company’s accounting records and reports will be maintained in a fair and accurate manner in accordance with all applicable laws and consistent with all generally accepted accounting standards.  In addition, all employees will comply with and take all reasonable action to ensure others comply with all applicable governmental laws, rules and regulations.

Relationships with Physicians

There are many forms of interactions between Globus and Physicians that advance medical science and improve patient care, including:

Advancement of Medical Technology. Developing new medical technology and improving existing products are collaborative processes between Globus and Physicians.

Safe and Effective Use of Medical Technology. The safe and effective use of sophisticated surgical technology often requires Globus to offer Physicians appropriate instruction, education, training, service and technical support. Regulators may also require this type of training as a condition of product approval.

Research and Education. Members’ support of bona fide medical research, education, and enhancement of professional skills serves patient safety and increases access to new technology.

Product Training and Education
Globus has a responsibility to make product education and training available to Physicians. In fact, the U.S. Food and Drug Administration mandates training and education to facilitate the safe and effective use of certain medical technology. Globus adheres to the following criteria with regard to these training and educational programs.

Programs and events  are conducted in clinical, educational, conference, or other settings conducive to the effective transmission of knowledge.

Programs requiring “hands on” training in medical procedures are held at training facilities, medical institutions, laboratories, or other appropriate facilities. The training staff have the proper qualifications and expertise to conduct such training.

Globus may pay for reasonable travel and modest lodging costs incurred by attending Physicians.

Globus does not pay for the meals, hospitality, travel, or other expenses for guests of Physicians or for any other person who does not have a bona fide professional interest in the information being shared at the meeting.

Consultants
Many Physicians serve as consultants to Globus, providing valuable bona fide consulting services, including research, participation on advisory boards, presentations at Globus-sponsored training and product collaboration. It is appropriate to pay Physicians reasonable compensation for performing these services. The following factors support the existence of a bona fide consulting arrangement between Globus and a Physician:

• Globus consulting agreements are written and signed by the parties and specify all services to be provided. Globus does not engage Physicians for services on a fixed or retainer basis. All payments made are for actual work performed.
• Compensation paid to consultants is consistent with the fair market value for the services provided.
• Consulting agreements are entered into only where a legitimate need and purpose for the services is identified in advance.
• Selection of consultants is made on the basis of the consultant’s qualifications and expertise to address the identified issues.
• Globus may pay for reasonable and actual expenses incurred by consultants in carrying out the subject of the consulting arrangement.
• When Globus contracts with a consultant for research services, there is a written research protocol established.