Confindustria Dispositivi Medici Globus Medical Italian Disclosure Methodology

Preamble

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 Code of Ethics. Where an 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.

This year’s disclosure will include all Transfers of Value that were entered into as of January 1, 2024, and all the data from previous years will remain published for a period of 3 years from the time of publication.

What Transfers of Value inclusion rules do we use?

The Transfers of Value will be included in our disclosure report for the calendar year in which payment was executed in our financial systems.

How are different currencies handled?

All values reported are in Euros. For Transfers of Value that were originally made in non-local currency, a conversion to the local currency is made based on the exchange rates on the date of transfer.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.

VAT treatment

Globus has taken the decision to report values including VAT wherever possible due to the complexity of VAT regimes around Europe and the inconsistency of whether VAT may or may not be reimbursable depending on where the transaction took place and the country of residency of the HCP or HCO. All other taxes are included in the reported values. If the amount including VAT is not available, the net amount is disclosed.

Disclaimer

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.