Globus Medical, Inc. (“Globus”) is committed to maintaining the highest ethical and legal standards in all of our activities. We believe that maintaining these standards is an essential part of our effort to be recognized by surgeons, patients, and others as being one of the pre-eminent spine companies in the world. As part of that effort, Globus has developed policies, procedures, and training designed to ensure that our business is run ethically, in compliance with relevant laws and regulations, and in a manner that furthers our goal of improving patient outcomes. As a leader in our industry both in what we do and how we do it, our Corporate Compliance Program furthers our belief that our activities should benefit patients, enhance the practice of medicine, comply with all applicable legal standards, and not interfere with the independent judgment of healthcare professionals.
As part of our compliance program, Globus has established a hotline (U.S. 855-688-1728) and website (www.globusmedical.ethicspoint.com) that can be used to report compliance concerns. For international dialing, please visit www.globusmedical.ethicspoint.com to determine the appropriate phone number to call based on your location. The hotline and website are important resources for anyone with a question or concern about a Globus policy or practice, or for anyone who wishes to report a suspected violation of the law or Company policy. The Globus Medical Compliance Hotline and website may be used by any individual to report a compliance concern including, but not limited to, concerns in the following areas:
- Violations of applicable laws and regulations both in the United States and Internationally
- Violations of the AdvaMed Code of Ethics
- Violations of the MedTech Code
- Violations of the Globus Code of Ethics
- Violations of any Globus policy
- Concerns about Globus’ accounting, internal control, or auditing practices
- Other general compliance concerns
When calling the hotline, a trained specialist from Global Compliance (the third-party company providing the service – not an employee of Globus) will take the call, listen, and ask questions about the concern. Individuals who report will receive a unique case number and date so they may follow up on their concern and receive updates as to the resolution of the matter. A report of the call is forwarded to the Compliance Office for action. If the website is used, a similar process will be followed.
Globus Compliance works promptly to respond to each reported matter. In the U.S. and most other countries, individuals are able to report anonymously. All reports, regardless of content, may be made without fear of retaliation and with complete assurance that it will be thoroughly investigated.