Introduction and Scope

Baxano is an active member of the Advanced Medical Technology Association (AdvaMed), and has voluntarily adopted AdvaMed’s Code of Ethics on Interactions with Health Care Professionals, which is intended to help the medical technology industry facilitate ethical interactions with the healthcare community.

Baxano is committed to following the seven elements of an effective compliance program as set forth in the voluntary “Compliance Program Guidance for Pharmaceutical Manufacturers” published by the Office of Inspector General, U.S. Department of Health and Human Service. These seven elements are described in the Procedure section. The Baxano program also requires compliance with the California Health and Safety Code § 119400-119402 and the voluntary Pharmaceutical Research and Manufacturers of America’s Code on Interactions with Healthcare Professionals.

This procedure requires Baxano management, employees, independent dealers, distributors and agents of the Company to act in accordance with law and applicable company policy.