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RTI’s culture embraces a commitment to serving patients and honoring donations, a passion for winning, continuous improvement, customer-centricity, collaboration and accountability. Our Corporate Compliance program is integral to bringing these values to life and fulfilling our client promise by helping ensure we conduct all business activities with integrity and in accordance with applicable guidelines, rules and regulations.

MedTech Europe

As a member of MedTech Europe, RTI is committed to ensuring that our collaboration with healthcare professionals adheres to the highest ethical and professional standards. These standards are encompassed in the MedTech Europe Code of Ethical Business Practice, which is intended to provide the minimum ethical standards and principles for the medical technology industry across Europe. It is designed to supplement, but not replace, any national laws or regulations or other professional or business codes which may apply to MedTech Europe members.

RTI Surgical, Inc. Statement on Slavery and Human Trafficking

California Transparency in Supply Chains Act Disclosure
RTI Surgical, Inc. (including its subsidiaries) (“RTI”) is strongly opposed to human trafficking and slavery and supports efforts to eradicate such practices. RTI would never knowingly conduct business with contractors or suppliers engaged in such practices.

Given the nature of the types of products, implants and services we provide, it is our assessment that our business activities present little risk of promoting human trafficking and slavery. With respect to these issues, the California Transparency in the Supply Chains Act of 2010 (the “Act”) requires certain manufacturers and retailers, including RTI, to disclose their efforts to eradicate human trafficking and slavery from their supply chains. The Act requires disclosure in five (5) areas: audits, verification, certification, training, and internal accountability. At this time, RTI does not audit or independently verify its product supply chain or its direct suppliers for risks relating to human trafficking or slavery. According to the RTI Code of Conduct and our contractual arrangements with suppliers, our suppliers are required to comply with applicable laws and regulations governing their business practices. Failure to comply with these contractual requirements constitutes breach of contract, but there is no separate certification process specifically for slavery and human trafficking. RTI has incorporated information on addressing the potential for human trafficking or slavery in its supply chain into our regular training curriculum for employees and management with direct responsibility for supply chain management. The RTI Compliance Program provides internal accountability procedures for these issues.

Visit End Human Trafficking Now for more information about trafficking and the global fight to end it.

Anonymous Reporting

RTI consistently strives to deal with stakeholders in the most fair and ethical manner possible. We provide multiple channels for reporting concerns regarding ethical interactions with health care professionals and suspected instances of violations of law or improper conduct in the company. The company has duty to report non-retaliation and confidentiality policies to encourage and protect colleagues who raise a valid concern.

Should you have questions or concerns about an ethics and/or compliance issue, or have questions about our compliance program, please contact any of the following:

RTI Corporate Compliance and Ethics Office: compliance@rtix.com
RTI Ethics and Health Care Compliance Hotline: 844-969-1165 or www.rtisurgical.ethicspoint.com

Data Privacy

RTI Surgical is committed to the protection of the data privacy of individuals, health care providers and institutions and entities with whom we conduct business. We have appropriate administrative and security policies and procedures that comply with U.S. and international privacy and data protection requirements. If you have any questions about your data privacy please our Data Protection Officer at DPO@rtix.com.

For More Information

• Data Privacy
• Global Data Protection Regulation (GDPR)
• California Consumer Privacy Act
• Corporate Citizenship - Payments to Physicians

Corporate Citizenship – Payments to Physicians

Physician Payments Sunshine Act
The Physician Payments Sunshine regulation (“Sunshine” or “Open Payments”) requires manufacturers of products reimbursed by Medicare or Medicaid (so-called “covered products”) and certain of their affiliates that operate in the United States to annually report to the Centers for Medicare and Medicaid Services (“CMS”) information about payments or other transfers of value they provide to U.S. physicians and teaching hospitals (collectively, “covered recipients”).

Any payment or transfer of value from a manufacturer operating in the United States to a covered recipient must be reported. Some examples are:

• Meals provided both in and out of the physician’s office
• Physician educational items that do not directly benefit the patient, including textbooks and scientific journal reprints
• Payments for speaking engagements
• The information will be posted on CMS’s Enterprise Portal

For questions related to information reported on you, send an email to compliance@rtix.com.

The information provided on this page does not constitute legal advice and is intended for educational purposes only. You should consult with your legal counsel for answers to any specific questions you may have. All information on this page is subject to change as a result of a change in law, regulation or guidance from CMS. For the most up-to-date information on Sunshine, please consult the Open Payments section on the CMS website.