Corporate Compliance

Corporate Compliance


As part of our commitment to the highest ethical standards and good corporate citizenship, we developed a Corporate Compliance program to assist in conducting all of our business activities with integrity and in accordance with applicable guidelines, rules and regulations.

RTI Surgical Corporate Compliance and Ethics Program Infrastructure

Board Nominating & Governance Committee The Board Nominating & Governance Committee is charged with ensuring the establishment and maintenance of an effective compliance program designed to prevent and detect violations of law.
Sr. Director of Corporate Compliance and Internal Audit Christopher Gingras serves as the Sr. Director of Compliance and Internal Audit and directs the Corporate Compliance and Ethics Program.
Senior Leadership Team The RTI leadership team supports a culture of compliance that permeates the organization.

AdvaMed

The Advanced Medical Technology Association (AdvaMed) is dedicated to the advancement of medical science, the improvement of patient care, and in particular to the contribution that high quality, cost-effective health care technology can make toward achieving those goals. In pursuing this mission, AdvaMed members recognize that adherence to ethical standards and compliance with applicable laws are critical to the medical device industry's ability to continue its collaboration with health care professionals.

Members encourage ethical business practices and socially responsible industry conduct related to their interactions with health care professionals. Members also respect the obligation of health care professionals to make independent decisions regarding Member products.

Consequently, AdvaMed adopted this voluntary Code of Ethics, effective January 1, 2004, and revised and restated with an effective date of July 1, 2009, to facilitate Members' ethical interactions with those individuals or entities that purchase, lease, recommend, use, arrange for the purchase or lease of, or prescribe Members' medical technology products in the United States.

Eucomed

As a member of Eucomed we are committed to ensuring that our collaboration with HCPs adheres to the highest ethical and professional standards. These standards are encompassed in the Eucomed Code of Ethical Practices.

This Code of Ethical Practices 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 Eucomed 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.

Health Care Compliance

The company has established a Corporate Compliance and Ethics Office to establish programs as well as monitor activity and concerns regarding ethical interactions with Health Care Professionals (HCPs). If employees feel it is appropriate, they may contact the Compliance Office directly to report suspected violations, or matters can be reported using the anonymous RTI Ethics and Health Care Compliance Hotline. The Compliance Office can be reached at rticompliance@rtix.com and the hotline information is referenced below.

Corporate Ombudsman

The company has established a Corporate Ombudsman to address certain SEC and workplace issues. SEC and workplace issues should first be discussed through normal supervisory channels, with a Human Resources representative or by using the Healthcare Compliance Hotline. If employees feel it is appropriate they may reach the Corporate Ombudsman directly at ombudsman@rtix.com.

Anonymous Reporting

The Ethics and Healthcare Compliance Hotline is a resource for any employee to report suspected instances of violations of law or improper conduct in the company. Any employee who is concerned that any other employee has violated or may violate any law or corporate policy, may report the concern utilizing the above reporting options or use the anonymous hotline at 855-231-0619 or at www.rtisurgical.ethicspoint.com.

Contact Information or Questions

RTI provides multiple channels for reporting general issues and raising compliance concerns. The company has duty to report, non-retaliation and confidentiality policies to encourage and protect colleagues who raise a valid concern.

RTI consistently strives to deal with our stakeholders in the most fair and ethical manner possible. 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:

Health Care Compliance
Ombudsman

Christopher R. Gingras
Sr. Director of Corporate Compliance & Internal Audit
11621 Research Circle
Alachua, FL
(386) 418-8888
cgingras@rtix.com

Human Resources
Paul A. Montague
Vice President, Human Resources
11621 Research Circle
Alachua, FL
(386) 418-8888