Ethics and Integrity

Trust is one of our most valuable assets, and it’s one of the most fragile. At LivaNova, our integrity is the foundation of that trust. We do not commit - or become involved in – bribery, corruption or fraudulent behavior. We want to be successful because of the quality and performance of the products and services we provide, and not because of unethical shortcuts. We all value honesty, transparency, and integrity in the company that we work for - this policy is our commitment to those values.

This policy is available in the following languages – click on the language to access the document:

• Arabic
• Chinese (simplified)
• French
• German
• English
• Italian
• Japanese
• Portuguese
• Spanish
• Thai

In this section, you will find information related to the transfer of values that LivaNova provides to Italian Healthcare Professionals and/or Healthcare Organizations.
 
What are the requirements?
 
Confindustria Dispositivi Medici request from their Members to 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.
 
What is the frequency?
 
LivaNova shall publish the transfers of value made each year within the first six months of the following year.
 
2021 Transparency Report - Italy

2021 Methodology Note

2020 Transparency Report - Italy
 
2020 Methodology Note

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

LivaNova is a worldwide leader in cardiovascular and neuromodulation solutions, dedicated to creating meaningful products and therapies that transform lives each and every day. We understand and respect the obligation we have to our patients and their families and caregivers as well as to our business partners and the environment at large. We operate 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, per our Code of Ethics and Business Conduct, which is located here: https://investor.livanova.com/corporate-governance/code-of-business-conduct-and-ethics.

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 all 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 (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.

Access the Third Party Code of Ethics and Business Conduct in the following languages:

• English
• Chinese
• Japanese
• Portuguese
• Spanish
• Russian

2022 Modern Slavery and Human Trafficking Statement

Approved 19 April 2023 by the LivaNova Board of Directors

LivaNova supports the goals of the California Transparency in Supply Chains Act of 2010 and the United Kingdom Modern Slavery Act of 2015 and is committed to eradicating modern slavery and human trafficking from our business activities and supply chains. This statement sets out LivaNova’s commitment towards these efforts for the fiscal year starting 1 January 2022 and ending 31 December 2022.

LivaNova is a worldwide leader in cardiovascular and neuromodulation solutions, dedicated to creating meaningful products and therapies that transform lives each and every day. With approximately 2900 employees worldwide, and operating in over 100 countries, we are committed to the highest ethical standards and compliance with laws and regulations applicable to our business, including laws related to modern slavery and human trafficking.

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.

2022 Modern Slavery and Human Trafficking Statement

Archived Statements
2021 Modern Slavery and Human Trafficking Statement Archived
2020 Modern Slavery and Human Trafficking Statement Archived
2019 Modern Slavery and Human Trafficking Statement Archived

We strive to conduct our activities in a manner that reflects our mission and Code of Ethics and Business Conduct – which includes being a good corporate citizen, dealing fairly in business, behaving ethically, supporting a safe and healthy workplace, doing business in an environmentally responsible manner, and complying with applicable law. 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. In addition, we expect our suppliers to conduct business operations in an ethical manner to comply with our Third Party Code of Ethics and Business Conduct and all applicable laws related to environmental responsibility, workplace health and safety, and human resources.
 
View our Conflict Minerals Report.

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.

Global Anti-Harassment and Anti-Discrimination Policy

Gender Equality Index France/Index Égalité Femmes-Hommes France  

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 of our Code of Ethics and Business Conduct, a related policy, any integrity concern or against anyone who participates in an investigation resulting from a report. Our Global Speak Up and Non-Retaliation Policy provides more information about LivaNova’s commitment to psychological safety and a culture of openness, transparency and continuous improvement. This policy is available in the following languages – click on the language to access the document:

• Arabic
• Chinese 
• English
• French
• German
• Italian
• Japanese
• Portuguese
• Spanish
• Thai

You have several options on how to Speak Up:  

Phone

(800) 461-9330 (Additional local numbers are available here.)
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. 

Web

https://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.

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.

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 and its ethics & compliance policies, procedures and guidance documents are made available 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 risk areas and related policies and procedures, as applicable. Every year, all 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.

Last Updated: September 2022

These industry guidelines, along with the LivaNova Corporate Code of Conduct and LivaNova Corporate Compliance Policies, are the foundation of LivaNova's Compliance Program.