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Manual MedEd teste 3

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Arthrex Compliance Policy<br />

We always compete vigorously. However, we must take care to avoid<br />

any unlawful or unethical conduct. Such conduct undermines the trust<br />

that our customers place in us and their trust is the foundation of our<br />

success. As a manufacturer of medical devices, we follow the applicable<br />

industry codes including AdvaMed (which governs interactions with<br />

HCPs in the US), EucoMed (governing Europe), as well as others. In<br />

some regions, local laws and industry codes may be more stringent than<br />

this Code; in those cases, the most stringent laws or codes apply. If an<br />

event involves individuals from more than one country (for example,<br />

an HCP from one country receiving product training in another), you<br />

should take care to comply with the requirements of both countries,<br />

to the extent they apply. The purpose of these industry laws and codes<br />

is to ensure medical decisions are based on the best interest of the<br />

patient and that the collaborative business relationships of medical<br />

device manufacturers meet high ethical standards and are conducted<br />

with appropriate transparency and in compliance with applicable laws,<br />

regulations, and government guidance.<br />

We carry out our duties and responsibilities in a fair,<br />

objective manner. We make legal and ethical business<br />

decisions in the best interest of our company, free from<br />

personal or external interests. Conflicts of interest can<br />

occur anytime your personal interests might benefit from<br />

your actions or influence as an Arthrex® employee.<br />

Outside business interests with our vendors, suppliers,<br />

customers or competitors are a particular cause of<br />

concern. Having outside business interests that interfere<br />

with your obligation to devote your time and attention<br />

to your job responsibilities, or behaving in a manner<br />

that reflects adversely on Arthrex, can result in a conflict<br />

of interest. If an employee or their immediate family<br />

member(s) have any outside interests as noted above,<br />

the employee is obligated to disclose this information<br />

to their manager when consistent with local laws. It is<br />

important both to disclose relevant facts before you, or<br />

your immediate family members, become involved in or<br />

acquire a financial interest in an outside business and<br />

to take any actions we require to resolve any potential<br />

conflict of interest that is identified.<br />

Who is responsible for it?<br />

Sponsor - Arthrex Subs or Distributors<br />

HCP - Healthcare Professional<br />

The following guidelines should lead your decision on:<br />

I. Conflicts of Interest:<br />

II.<br />

Gifts:<br />

Gifts by Arthrex employees or agents to customers<br />

are generally prohibited. There is an exception to this<br />

general rule for: 1) Occasional modest gifts to Health<br />

Care Professionals (HCPs), but only if the gift benefits<br />

patients or serves a genuine educational function for<br />

HCPs, such as medical textbooks or anatomical models<br />

used for educational purposes. (See AdvaMed Code of<br />

Ethics on Interactions with Health Care Professionals,<br />

Section IX., Educational Items; Prohibition of Gifts,

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