|Nominating & Corporate Governance Committee|
|Lead Independent Director|
NuVasive Global Business Ethics and Compliance Program
|Commitment to Business Ethics and Compliance|
NuVasive is committed to conducting all of its business activities in accordance with the highest standards of ethics, professionalism, integrity, responsibility, and accountability. No commercial objective is more important that conducting our business ethically and in full compliance with all applicable federal, state, and local laws, especially those designed to prevent fraud and abuse. In order to ensure such compliance, NuVasive has adopted a comprehensive compliance program, entitled NuVasive Global Business Ethics and Compliance Program ("Program"), which is designed to prevent and detect unethical business conduct, or violations of law or company policy.
It is NuVasive policy that all of its officers, directors, employees, agents, and independent contractors* comply with the Program and the policies and procedures created to support the Program. In the event NuVasive becomes aware of a violation of law or company policy, it will investigate the matter and, where appropriate, take disciplinary action and implement any necessary corrective measures to prevent reoccurrence.
The Program is designed to adhere to the requirements as set forth in the U.S. Federal Sentencing Guidelines and recommendations contained in the OIG's compliance program guidance. The Program is dynamic and is regularly reviewed and enhanced it to meet the company's evolving business ethics and compliance needs. The following is an overview of the elements of the Program:
- Written Standards. NuVasive has adopted written standards regarding compliance, including a Code of Ethical Business Conduct (required reading for each employee), a notice regarding our Commitment to Compliance (posted at each location) and appropriate policies and procedures.
- Leadership and Structure. NuVasive has appointed a Compliance Officer and established two tiers of Compliance Committees consisting of upper and middle management from various departments to implement and monitor its Program.
- Education and Training. NuVasive has developed a training program tailored to each employee's individual responsibilities, including training regarding compliance with our Program, Code and specific laws and regulations, such as the Food Drug & Cosmetic Act, Medicare fraud and abuse laws (e.g., Anti-Kickback Statute; False Claims Act), Foreign Corrupt Practices Act, and other applicable federal, state, and local laws, rules, and regulations.
- Internal Lines of Communication. NuVasive has established a confidential disclosure program (the "Integrity Hotline") that permits employees to anonymously disclose ethical, legal, and compliance concerns through a toll-free telephone number that cannot be traced.
- Audit and Monitoring. NuVasive conducts routine and random audits to ensure compliance with all legal and regulatory requirements.
- Enforcement and Discipline. NuVasive has created written disciplinary guidelines to address any issues of non-compliance and such guidelines have been communicated to all employees and are consistently enforced.
- Corrective Action Procedures. NuVasive investigates any and all ethical, legal, and compliance issues raised and takes appropriate action to resolve any such matters and prevent reoccurrence.
*The term "independent contractor" includes only those individuals who perform the type of core job functions or services on behalf of NuVasive that would otherwise be provided by an employee.
To see a copy of the NuVasive Global Business Ethics and Compliance Program, please click here.
To see a copy of the NuVasive California Comprehensive Program Overview, please click here.
To see a copy of the NuVasive California Declaration to its Program, please click here.
In August 2015, NuVasive revised the Code of Ethical Business Conduct. The purpose of the revisions was to improve readability by implementing a new format and design in order to provide additional guidance and more clearly communicate the ethical and legal commitments of NuVasive and its employees, officers, directors and agents.
To see a copy of the NuVasive Code of Ethical Business Conduct, please click here.
For questions or comments regarding our compliance program, please call, toll free, the NuVasive Integrity Hotline at 1-866-907-7409 or e-mail us at ComplianceOfficer@NuVasive.com.BACK TO TOP