Procedures

Leadership

The Compliance Committee is comprised of members of senior management (including the CEO) and assists in the implementation of the Compliance Program. They designate a Compliance Officer (CO) and ensure that the CO has the ability to effect change within the organization as necessary and to exercise independent judgment. 

The Compliance Officer (CO) is responsible for developing, operating and monitoring the Compliance Program. 

Written Standards

The Baxano Ethics and Compliance Responsibility Statement and this Operating Procedure are the foundation of the Baxano program. It includes the basic requirement of compliance with all applicable laws and regulations. The compliance program places restrictions and internal controls to address more specific areas of compliance risk within our business.

Training and Education

Ethics and compliance training is a major component of the Baxano program, including the education of relevant employees on the company’s obligations under applicable laws, regulations and standards. Baxano provides training through interactive computer-based programs and live sessions with subject-matter experts.

Internal Lines of Communication

Baxano provides a toll-free confidential Ethics and Compliance Helpline and employees are encouraged to ask question and discuss concerns. Additionally, Baxano promotes direct employee communication with management, human resources and the Compliance Officer. The company will not tolerate retaliation against anyone who makes a good faith report regarding a potential violation of the policies and procedures of the Compliance Program or the law.

Internal Monitoring and Auditing

The Baxano Compliance Program includes ongoing monitoring, auditing and evaluation of compliance with the program requirements. This information is also periodically presented by the CO to the Compliance Committee for assessment.

Enforcing Standards through Disciplinary Guidelines

The Baxano Program provides clear communication regarding the compliance expectations and the consequences of violating the law or company policy, including disciplinary actions. Disciplinary action may, when appropriate, include dismissal.

Responding to Problems and Corrective Action

The Baxano program includes a process for identifying and promptly investigating potential violations, and taking action to correct inappropriate conduct and deter future violations. This process is managed by the CO.