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Ethics & Integrity

LivaNova operates within a framework of principles, guidelines and policies aligned with ethical, social and environmental responsibilities, and we abide by the highest standards of business ethics and compliance. We are guided by our Code of Ethics and Business Conduct (also referred to as “Code of Conduct”) that applies to all employees and board directors of LivaNova and its subsidiaries, and sets the tone for our global ethics and compliance program.

Ethics & Integrity Policies

Ethics and Compliance Program

Business Integrity Policy

Anti-Harassment/Discrimination

Speak Up

Third Party Code

Modern Slavery

Conflict Minerals

Industry Affiliations

Transparency in Italy

At LivaNova, we are committed to maintaining an effective and comprehensive ethics and compliance program. As a manufacturer of medical devices, LivaNova has designed a Global Ethics & Integrity Program to comply with all applicable laws, regulations and industry codes related to the ethical and compliant promotion and sales of our products in the countries where we operate. Our ethics and compliance program includes the following:

  1. Code of conduct. Our Code of Ethics and Business Conduct is available in multiple languages.
  2. Written policies and procedures. Our compliance policies, procedures and guidance documents are made available to our employees via our company intranet.
  3. Assigned compliance officer. LivaNova has assigned a Chief Ethics & Integrity Officer who is responsible for implementing our ethics & compliance program.
  4. Comprehensive training and education. LivaNova is committed to providing our employees with relevant compliance training and education on our policies and procedures.
  5. Clear lines of communication for compliance reporting. LivaNova encourages a safe environment for all employees to Speak Up and raise concerns.
  6. Monitoring and auditing. LivaNova actively audits and monitors key processes to ensure compliance with the Company’s policies and procedures.

The LivaNova Code of Conduct, Business Integrity Policy, Third Party Code of Conduct and various other company policies and procedures are made available in multiple languages to internal users and, where applicable, to external ones. To ensure awareness and understanding of the Company’s ethical standards and expectations, corporate employees are introduced to our Ethics & Integrity (E&I) program upon onboarding and provided training throughout their employment on an ad-hoc basis on selected policies and procedures, if and as applicable. Every year, employees certify their acknowledgement and commitment to our Code of Conduct.

Underpinning and surrounding LivaNova’s ethics & compliance program is an intricate yet dynamic web of risk-assessment, monitoring and auditing activities. In order to effectively maintain such a sophisticated program, leadership engagement is of the essence. As part of the smooth running of the program, various members of the E&I team hold regular touch-points, educational and update sessions with local leadership. In addition, overview sessions with senior leadership are held throughout the year, typically on a monthly basis, by the Chief E&I Officer and/or delegates.

Update and engagement sessions are organized with different members of the Executive Leadership Team in order to draw their attention to business integrity related matters, conflicts and “hot topics” within their function, region or business unit of responsibility. This initiative has proven effective in ensuring timely communication and continuous improvement through proactive collaboration across different parts of the company on various important compliance topics, while at the same time solidifying our culture of ethical leadership across the organization.

Overall oversight of LivaNova’s ethics and compliance program – designed, implemented and managed by the E&I function — lies with the E&I Committee and, ultimately, with the Audit and Compliance Committee of the LivaNova Board of Directors, which is responsible for the review and oversight of the LivaNova Ethics & Integrity program.

To our knowledge, LivaNova is, in all material respects, in compliance with the California Health and Safety Code, Sections 119400-119402. Copies of this declaration, as well as additional details regarding our LivaNova Ethics & Integrity Program, may be obtained by calling the LivaNova Ethics Line at +1-800-461-9330.

Our Business Integrity Policy is at the foundation of our behavioral standards. In line with our Code of Conduct, this policy highlights the importance of trust as a key pillar of our work-related interactions with others (including, but not limited to, healthcare professionals, patients, customers, suppliers and colleagues), emphasizing in particular the Company’s stance against misconduct in the areas of corruption, bribery and fraud.

At LivaNova, we value integrity, honesty and transparency – all of which create the foundation upon which trust is based. Trust is one of our most valuable assets, and it’s one of the most fragile. This policy states our committment to building success on the quality and performance of our products and services, not on unethical shortcuts.

At LivaNova we seek to unite people. We value diversity and offer the same welcome to all employees and partners regardless of race, gender, nationality, ethnic origin, religion, age or sexual orientation. Everyone should be treated with dignity and respect. Bullying, intimidation or harassment of any kind is not acceptable in our workplace.

LivaNova conducts awareness and communication activities to ensure employees know that they are invited to speak up (and how to do it) whenever they have concerns about unethical behavior. Our Speak Up and Non-Retaliation Policy provides details about LivaNova’s whistleblowing channels, underlining the company’s commitment to psychological safety and to a culture of openness, transparency and continuous improvement. 

As part of our Speak Up Program, LivaNova maintains a 24/7 Ethics Line — available to employees as well as third parties — for reporting concerns via web, email or phone, in multiple languages. 

At LivaNova, we believe it is the responsibility of all stakeholders to ensure we remain reputable leaders in compliance and business ethics. 

We encourage a safe environment for all individuals to speak up and raise any concerns they may have as it relates to the LivaNova Code of Ethics and Business Conduct, a related policy or any integrity issue. LivaNova does not tolerate any form of retaliation against an individual arising from a good-faith report of a potential violation or against anyone who participates in an investigation resulting from a report. 

Our Global Speak Up and Non-Retaliation Policy

Options to speak up

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Phone

(800) 461-9330

The LivaNova Ethics Line is a toll-free telephone line managed by a third-party provider. If requested and allowable by local law, reporters will be granted full anonymity. The hotline is available globally and in multiple languages. Additional local numbers

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Web

ethicshelpline.livanova.com

The LivaNova Ethics Line can also be reached via web through our third-party managed, confidential and anonymous (if requested and allowable by local law) online reporting tool.

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Email

Ethics@Livanova.com

The LivaNova Ethics Inbox is managed by Corporate Compliance and any concerns received will remain confidential.

Reported matters are logged into a database where they are tracked, triaged and investigated according to our internal investigation process. Disciplinary measures or other corrective action stemming from investigations, if any, are also documented in the database and tracked through their completion under our framework of self-accountability and continuous improvement. Related internal governance procedures ensure that Ethics Line metrics and high-severity cases (Serious Reportable Matters) are reported, at least quarterly, by the Chief E&I Officer to the E&I Committee, which consists of the CEO, CFO, General Counsel, Chief E&I Officer, VP of Internal Audit and VP of Risk. In addition, also on a quarterly basis, the Chief E&I Officer reports all Serious Reportable Matters that were opened or closed during the previous quarter to the Audit and Compliance Committee of the LivaNova Board of Directors. Where applicable, immediate escalations and referrals directly to the Chair of the Audit and Compliance Committee are handled by the Chief E&I Officer in accordance with our internal investigation procedure. In managing Speak Up matters, investigations and escalations.

LivaNova strives to put the protection of bona fide whistleblowers and victims at the forefront, while maintaining confidentiality and anonymity per local laws. LivaNova’s designated investigators are trained on the skills and tools needed for conducting and documenting internal investigations in compliance with company policies, procedures and applicable regulatory requirements, which include — among other requirements — measures for the safeguard of involved parties from retaliation in any form or shape.

Reminders about speak-up and non-retaliation topics are part of compliance training sessions, sales meetings, top leadership gatherings or CEO Town Halls – to help employees feel safe speaking up when something doesn’t look right.

LivaNova embraces the key principles of the International Labour Organization’s fundamental conventions. We believe that our business can only succeed where the rights of workers involved in the value chain of our business are protected and respected, and we aim to conduct business with third parties including consultants, suppliers and other business partners (Third Parties) who share our commitment to operating in a responsible and ethical manner.

Accordingly, this Third Party Code of Ethics and Business Conduct (Third Party Code of Conduct) outlines the minimum standards we require all LivaNova Third Parties to comply with when doing business with us, in addition to all applicable laws, regulations and industry standards. It covers areas such as human rights and labor conditions, the environment, trade compliance, and confidentiality and data privacy.

Third Party Code of Ethics and Business Conduct

LivaNova is committed to the highest ethical standards and compliance with laws and regulations applicable to our business, including laws related to slavery and human trafficking.

This statement sets out the Company's commitment towards these efforts for the 2021 fiscal year.

As part of our initiative to identify and mitigate risks relating to modern slavery, LivaNova has taken the steps described further in this statement and is continuously working to further improve our policies and practices to ensure: 1) materials and services provided to LivaNova are procured only from suppliers who share our same level of commitment, and 2) modern slavery does not exist within our own business operations.

We are committed to ensuring that our supply chain reflects our values and beliefs, including adherence to principles of responsible sourcing for materials for our products. As part of our commitment, LivaNova supports the goals and objectives of Section 1502 of the Dodd Frank Act that requires public companies to determine the sourcing of conflict minerals used in their products. We expect our suppliers to support our efforts to comply with the Dodd Frank Act and to proactively identify and work towards eliminating the use of any minerals that fund or benefit armed groups from within our supply chain.

Conflict Minerals Report

To help navigate the complex compliance environment in which we operate, LivaNova has adopted the AdvaMed Code of Ethics on Interactions with Health Care Professionals, the APACmed Code of Ethical Conduct , the Mecomed Code of Ethical Business Practice and the MedTech Europe Code of Ethical Business Practice.

These industry guidelines, along with the LivaNova Code of Conduct and ethics & compliance policies, are the foundation of LivaNova's ethics and compliance program.

At LivaNova, our priority is to improve the lives of patients with our products and therapies. Without the help of our valued partners in the healthcare field, we would not be able to achieve this goal.

To build and maintain trust between the medical device industry, the healthcare players, and patients, we strive to continuously operate with quality and integrity in everything we do. This includes also complying with laws and rules regulating our interactions with healthcare professionals and organizations. In this regard, LivaNova follows all applicable transparency requirements within the jurisdictions we operate.

Confindustria Dispositivi Medici, an Italian medical association, requests that its members document and publish all direct and indirect transfers of value to healthcare professionals, healthcare organizations and third parties.

When necessary, a consent to process and publish personal data is to be provided by the healthcare entities. In the event the consent is not given, the data is published on an aggregated basis.

LivaNova shall publish the transfers of value made each year within the first six months of the following year.

For more information about the LivaNova Transparency Program, please email AskEI@livanova.com.