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:
- Code of conduct. Our Code of Ethics and Business Conduct is available in multiple languages.
- Written policies and procedures. Our compliance policies, procedures and guidance documents are made available to our employees via our company intranet.
- Assigned compliance officer. LivaNova has assigned a Chief Ethics & Integrity Officer who is responsible for implementing our ethics & compliance program.
- Comprehensive training and education. LivaNova is committed to providing our employees with relevant compliance training and education on our policies and procedures.
- Clear lines of communication for compliance reporting. LivaNova encourages a safe environment for all employees to Speak Up and raise concerns.
- 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.
