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Confindustria Dispositivi Medici Globus Medical Italian Disclosure Methodology


Globus Medical discloses the amount of Transfers of Value made over the course of the previous year to healthcare professionals (HCPs), healthcare organizations (HCOs) and other third parties (TPIs) as prescribed by the Confidustria Dispositivi Medici (CDM). Where a HCP does not give consent to the processing of personal data, Globus Medical shall in any case arrange for the publication of data on an aggregate basis.

In general, we follow the definitions and guidance from the CDM Code of Ethics. Where these guidelines are not specific the below questions and answers are designed to clarify the methodology, we use to include Transfers of Value from Globus Medical in our CDM disclosure report.

We include all Transfers of Value that were entered into as of January 1, 2021 and all the data will remain published for a period of 3 years from the time of publication.

What Transfers of Value inclusion rules do we use?

All our reportable Transfers of Value relating to a calendar year and known as per the date of submission, will be included in our public disclosure report.

The Transfers of Value will be included in our disclosure report for the calendar year in which payment was executed in our financial systems. In-kind support (e.g. appropriate travel and accommodations), will be included in the disclosure report for the calendar year in which the activity occurred.

How are different currencies handled?

All values reported are in local currency – EUR. For Transfers of Value that were originally made in non-local currency, a conversion to the local currency is made based on the exchange rates on the date of transfer. The details can be provided on a case by case basis.

What recipients’ address do we show in the disclosure report?

We will display the most recent address that we have in our database at the time of the reporting.


We rely on a combination of automated systems, standardized processes, and manual data entry from internal and external resources to record relevant data and report it. The information reported in this submission reflects our good faith and best efforts to comply with the requirements of CDM. Should we, despite our best efforts to ensure accurate reporting, fail to include complete and correct information in our submission, we will appropriately investigate and address in case of erroneous information.

The Transfers of Value disclosed as per CDM requirements are only used to meet the respective reporting requirements. The costs are not to be used as backup for any TAX Authority Reporting, or any other reporting similar to this.