Code of Conduct


INTRODUCTION, Inc. (“”) has adopted this Code of Conduct & Business Ethics (“Code”) regarding interactions with patients, healthcare professionals (“HCP”) and our business conduct within the industry generally. All interactions between and patients and HCPs must be carried out in a responsible, ethical, professional and legal manner. This Code describes the fundamental principles and standards to which all individuals must adhere, including board members, officers, employees, contractors, and agents (referred to in this Code of Conduct as “Company Representatives”). This Code sets a minimum standard. Laws and industry guidance that set higher standards, or more specific conditions, take precedence over this Code. will ensure that all Company Representatives are appropriately trained on the requirements of this Code. also will develop, implement and maintain a Corporate Compliance Program and other written Compliance Program Policies and Procedures that are consistent with this Code. Any conduct that violates this Code is prohibited. Compliance with this Code and related policies is mandatory. Violations can have serious consequences for and for Company Representatives. This Code incorporates principles set out in:

GENERAL POLICY STATEMENT’s reputation is attained through our individual business conduct. Integrity is central to our business success. is committed to conducting its business ethically and in compliance with all applicable laws, regulations, guidelines and policies in each geographical location and in each job function. Employees are expected to be proactive by acting legally and with adherence to our values and behaviors in a way that will merit the continued trust and confidence of the public. Every Company Representative of must:

  • Conduct his/her responsibilities in compliance with this Code;
  • Comply with’s Corporate Compliance Program and any written policies, procedures and other guidelines;
  • Protect’s reputation by actively supporting ethical behavior;
  • Promptly report any potential or actual non-compliance; and
  • Fully and honestly cooperate in any investigation of alleged violation of this Code or’s Compliance Program Policies and Procedures.’S CORPORATE COMPLIANCE PROGRAM is committed to conducting its business in compliance with the Federal and state laws, regulations and other requirements that govern our operations. provides resources to assist every individual within the Company, as well as our agents and vendors, to act in a legal and ethical manner.

Reporting Potential Violations

To encourage a workplace culture that keeps each Corporate Representative accountable to each other, provides several methods for individuals to make reports in an anonymous manner. These include a Compliance Hotline and other forms of confidential communication. Our policy is to ensure the all good faith reports of misconduct or noncompliance are immediately investigated. has a strict non-retaliation policy to protect Representatives who raise concerns in good faith. No action of reprisal or retaliation will be taken against any Representative for reporting a compliance concern or asking a question regarding our Compliance Program. Calls to the hotline or other types of reporting do not protect individuals from appropriate disciplinary action regarding their own performance or conduct.

Training and Education

The proper education and training of Company Representatives is a significant element of an effective compliance program. is committed to the education of its Company Representatives on issues related to corporate compliance. As such, has developed a training program that consists of compliance training to new hires and general training to all Company Representatives, and specific training sessions designed to target particular issues that only impact certain Company Representatives at Attention to training and compliance will be an integral part of the Company Representative evaluation process. Failure to comply with training and compliance requirements will result in disciplinary action, including possible termination.


HEALTH CARE LAWS AND REGULATORY REQUIREMENTS is committed to full compliance with all Federal and state laws and regulations applicable to our business, including but not limited to, the Federal Food, Drug and Cosmetic Act; Anti-Kickback Statutes; and patient privacy and confidentiality.

Fraudulent Conduct is Prohibited does not tolerate fraud and is committed to the rigorous investigation of any suspected cases of fraud. Should any Representative believe they have good reason to suspect a colleague or other individual is engaged in fraud or an offense involving or a serious infringement of the Code, he or she should report such unethical action his or her or supervisor to the CCO.

Privacy Requirements respects the confidential nature of patient health information. Therefore, must comply with all Federal and state health information privacy and security laws. Generally, unless otherwise permitted or required by law, will not disclose patient health information without prior authorization. and its business partners will limit the collection of, and access to, personal data to circumstances that are consistent with clinical quality and other specific, legitimate business needs and applicable laws and regulations. All personal data must be treated as confidential unless otherwise required, secured against unauthorized access, and retained only for as long as it is necessary. has adopted a number of additional Compliance Program Policies and Procedures addressing privacy issues that may affect its business activities.

Sanctioned/Excluded Individuals and Entities

The Federal government and many state agencies pay for’s products. Individuals and/or entities may be excluded, debarred or suspended from participating in Federal or state programs for various reasons, including inappropriate use of Federal or state funds. will not knowingly employ or contract with any individual or business which is excluded, debarred or suspended from participating in any government program. Generally:

  • will screen all Company Representatives against the appropriate Federal and state exclusion lists on a regular basis.
  • All Company Representatives have a duty to inform if their status on an exclusion list changes in any way.


Advertising and product promotion are activities that are strictly regulated. Company Representatives should understand the basic rules and policies follows to ensure compliance with the laws and regulations regarding promotional activities and advertising, including the following general guidelines:

  • Promotional material and communications must be accurate, balanced and not misleading in any respect. Claims must be compliant with medical, legal and regulatory standards.
  • All promotional material must be reviewed and approved by before use.
  • All promotional and advertising activities targeted toward patients will be in compliance with laws, regulations and Policies and Procedures.


Relationships with HCPs are heavily regulated and strictly enforced. An HCP is any individual or entity directly or indirectly involved in the delivery of health care services or items to patients and that can purchase, lease, prescribe, recommend, use or arrange for the purchase, lease or use of’s products or services.’s interactions with healthcare professionals, organizations and other authorities must be made in compliance with applicable laws, regulations, and Compliance Policies and Procedures. Our general policy can be expressed in two main points:

  • or its Representatives may not condition a financial arrangement or provide free services or grants to HCPs in exchange for any agreement to purchase, order or recommend products, or as a reward for high volume.
  • Payments to HCPs will only be provided to HCPs in exchange for the provision of services for which there is a legitimate business need and a written agreement that provides for fair market value compensation.


Ethical Business Practices is ethical and trustworthy in all of its business and interpersonal relationships and we are committed to competing fairly with integrity and in compliance with all anti-bribery, anti-trust and fair trade laws. and its Representatives must not offer any payment to public officials, politicians or political parties, either directly or indirectly, in an attempt to influence the behavior of any country’s administration, as required by the U.S. Foreign Corrupt Practices Act. and its Company Representatives must never engage in anti-competitive behavior that could illegally affect pricing or market share or lead to the abuse of a dominant market position. For example, Representatives should not agree or attempt to agree with a competitor to artificially set prices or salaries; or divide, restrict, or block market competition.

Respect for Diversity and Workplace Violence or Harassment respects the diversity of people, cultures, and ideas; we are people-focused and recognize our interdependence as one of’s core values. We value the unique contributions each individual brings to the workforce. treats its Company Representatives fairly, equally, compassionately and respectfully. We expect the same behavior from our Representatives and business partners. will not tolerate any form of harassment or discriminatory practice.

Violence, threats, harassment, intimidation and other disruptive behavior in our workplace will not be tolerated. Company Representatives that commit acts of violence or harassment may be removed from the premises and may be subject to disciplinary action, criminal penalties, or both.

Workplace Health and Safety requires its Company Representatives to be free of any measurable amounts of illegal drugs or alcohol in the workplace.

To protect the well-being of all Company Representatives and to maintain safe working conditions, all Representatives on premises must comply with workplace safety practices and promptly report any accidents. It is the responsibility of each individual to understand and comply with environmental, health and safety laws, regulations and policies relevant to your work.

Conflicts of Interest

Company Representatives must avoid any circumstances in which their personal interests create a conflict of interest with’s corporate interests or affect their ability to make good judgments consistent with their duty to

Conflict of interest issues typically arise in these settings:

  • Receiving gifts or favors from a customer or supplier;
  • Participating in activities that compete with our organization;
  • Allowing family or personal relationships to influence your business judgment; and
  • Giving or offering gifts or favors to government employees.

We believe that all Representatives owe a duty of loyalty to Therefore, Representatives must always abstain from engaging in activities that have the potential to be misinterpreted if publicly disclosed or where issues of actual or potential conflicts of interest could arise. Directors and officers must disclose any material transaction or relationship that could reasonably be expected to give rise to a conflict of interest.

Investment Activities and its Representatives, in communications with the investment community, are committed to providing judicious, accurate and balanced disclosure of material information regarding’s activities and achievements. Disclosures must be consistent with applicable legal and regulatory requirements.

Political Activity

While the right to free speech is at the core of our political system, the right to make political contributions and lobby government officials is heavily regulated by Federal and state laws. It is important to keep separate personal political activities from activities.

The rules regarding political activity can be summarized as follows:

  • We recognize Company Representatives’ right to vote and be politically active on their own behalf, on their own time and using their own resources;
  • Only’s designated representatives may speak on the organization’s behalf about politics, provided that the CCO has given prior written approval;
  •’s funds or resources will never be used for political activities, even if those funds are reimbursed; and
  • Company Representatives should never feel pressured to make a political contribution or to vote in a certain way by anyone working for or on its behalf.


All Representatives must abide by the letter and spirit of all applicable laws and regulations. Representatives must adhere to the highest ethical standards of conduct in all business activities. promotes relationships based on mutual trust and respect and provides an environment in which Representatives may question a practice without fear of adverse consequences. expects all of its Representatives to adhere to the Code in their dealings. The Code and Compliance Program are intended to establish a framework for legal and ethical conduct by and its Representatives. It is intended to reflect collective good judgment and common sense and it is intended to enhance our culture of compliance. Representatives have a responsibility to bring compliance concerns to the attention of their manager or the CCO. A Company Representative who has a question regarding the application or interpretation of the Code, laws and regulations or the Compliance Program Policies and Procedures should use the resources and procedures specified in the Corporate Compliance Program.