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 Corporate Code of Conduct and LivaNova Corporate Compliance Policies, are the foundation of LivaNova's Compliance Program.
At LivaNova, we are committed to maintaining an effective and comprehensive compliance program. As a manufacturer of medical devices, LivaNova has designed our Corporate Compliance Program to comply with all applicable U.S. state and federal laws related to the promotion and sales of our products. Our Corporate 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 Corporate Compliance Policies and Procedures are made available to our employees via our Company intranet. Assigned compliance officer. LivaNova has assigned a Compliance Officer who is responsible for implementing our Corporate Compliance Program. Comprehensive training and education. LivaNova is committed to providing our employees with comprehensive compliance training and education on all of our Corporate Compliance 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 compliance policies and procedures. 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 Corporate Compliance Program, may be obtained by calling the LivaNova Ethics Line at +1 800-461-9330. Last Updated: February 2021
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. 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.
Global Anti-Harassment and Anti-Discrimination Policy 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
Business Integrity Policy 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
California Transparency in Supply Chains Act and United Kingdom Modern Slavery Act 2020 Modern Slavery and Human Trafficking Statement Approved 21 April 2021 by the LivaNova Board of Directors LivaNova is a worldwide leader in cardiovascular and neuromodulation solutions, dedicated to creating meaningful products and therapies that transform lives each and every day. LivaNova PLC and its subsidiaries (individually or collectively, “LivaNova”), are committed to the highest ethical standards and compliance with laws and regulations applicable to our business, including laws related to slavery and human trafficking. LivaNova has approximately 4000 employees worldwide and operates in over 100 countries. This statement sets out LivaNova’s commitment towards these efforts for the fiscal year starting 1 January 2020 and ending 31 December 2020. 2020 Modern Slavery and Human Trafficking Statement Archived Statements 2019 Modern Slavery and Human Trafficking Statement Archived 2018 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 and to comply with our Code of Conduct and all applicable laws related to environmental responsibility, workplace health and safety, and human resources. View our Conflict Minerals Report.
Third Party Code of Ethics and Business Conduct 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. 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
Transparency in Italy At LivaNova, our priority is to improve our patients’ lives with our products and therapies. Without the help of our valued partners in the healthcare field (Healthcare Professionals and Healthcare Organizations), we would not be able to achieve this goal. To build and maintain trust between the medical device industry, the healthcare players, and the 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. 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. Link to the 2020 Transparency Report - Italy Link to the 2020 Methodology Note For more information about the LivaNova Transparency Program, please email AskEI@livanova.com.
