Sorin Code of Conduct

Sorin has adopted the AdvaMed Code of Ethics for Interaction with Healthcare Professionals. These guidelines, the Sorin Corporate Code of Conduct and Sorin's high ethical standards are the foundation of Sorin's Compliance Policies and Procedures Handbook. This handbook has several key policies of which employees, contractors, independent representatives and Sorin customers should be aware:

Compliance Committees

Sorin has formed Compliance Committees made up of key managers from several functions. The goal of each Committee is to ensure Sorin's compliance with relevant laws, regulations, and other industry standards. Each Committee is responsible for adopting all compliance policies and monitoring overall adherence to Sorin compliance policies and procedures.

Compliance Hotline

A compliance tool for employees, contractors, independent representatives or interested parties (such as: vendors or former employees, etc.) to report suspected unethical conduct or compliance violations of any kind. The hotline can be reached at 1-888-259-8571 or by clicking here.

Anti-Kickback Statute Policy

Sorin has established policies and procedures regarding the establishment of arrangements with individuals in a position to refer or recommend the purchase of Sorin products. Specifically, Sorin has established an arrangements review and tracking process designed to review each arrangement with an individual in a position to refer or recommend the purchase of Sorin products to ensure it does not violate the Anti-Kickback Statute or Sorin’s Compliance Policies and Procedures.

Meals and Entertainment Policy

The Committee has established guidelines on when providing meals to a health care professional is appropriate. The policy sets out a maximum limit of $150 per individual (excluding tax and tip) and also provides a limit on the frequency of providing meals to any one health care professional. Additionally, the policy provides outlines the new requirements for the states of Massachusetts and Vermont, which are currently more stringent.

Gifts

Gifts, formally a mainstay in many industries including the device industry, are no longer permitted in the state of Vermont. Outside Vermont, gift must not exceed a retail value of $100 and it must relate to patient care or serve a genuine educational function (e.g., textbooks, educational materials), Items related to the health care professional's work (e.g., pens, mouse pads, laser pointers, clip boards) or for a health care professionals personal benefit, such as t-shirts and golf balls, are not related to the health care provider's work or patient benefit and are prohibited. In addition, the gift must not take into account the actual or potential volume of referrals or other business generated by the healthcare provider.

Charitable Donations/Donated Product Policies

Sorin has established an Education and Charitable Support Committee which meets bi-monthly to evaluate requests for charitable donations, educational grants, event sponsorships and product donations. The goal of this committee is to ensure that donations to charitable entities or events will, in no way, be economically motivated or influenced by either the maintenance of current customers, employees or contractors and independent representatives or to encourage agreements with potential customers, employees or contractors and independent representatives. The charitable donation policy can be found on the Sorin North America Intranet and questions about the policy and what types of donations will be considered can be directed to soringroupethics@sorin.com.

Travel and Facility Tour Policies

This policy is designed to ensure ethical business practices are applied, and that bona fide arrangements are made in relation to facility tours, education and training provided to US health care professionals where travel and accommodations are paid by Sorin. This is includes national and international events.

Other Policies

Sorin has also established other policies covering basic compliance program elements, including;


Sorin's Compliance Policies and Procedures can be found on the intranet or by sending an e-mail to soringroupethics@sorin.com.