Responsibilities

The Compliance Committee is comprised 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.

Baxano management, employees, contractors, independent dealers, distributors and agents of the company are responsible to act in accordance with law and applicable company policy.

Employees are expected to know and follow the laws of each relevant market in which Baxano does business. Managers are expected to ensure such compliance.

It is the responsibility of every employee to promptly bring suspected violations of the Ethics and Compliance Program to the attention of the Company.

Managers must address employees’ concerns about appropriate conduct promptly and with care and respect.

Employees at all levels are prohibited from retaliating against or threatening anyone for reporting or supplying information about a policy or conduct concern.