Compliance

Our Business Integrity Policy is at the foundation of our behavioral standards. In line with our Code of Conduct, this policy highlights the importance of trust as a key pillar of our work-related interactions with others (including, but not limited to, healthcare professionals, patients, customers, suppliers and colleagues), emphasizing in particular the Company’s stance against misconduct in the areas of corruption, bribery and fraud.

At LivaNova, we value integrity, honesty and transparency – all of which create the foundation upon which trust is based. Trust is one of our most valuable assets, and it’s one of the most fragile. This policy states our committment to building success on the quality and performance of our products and services, not on unethical shortcuts.

At LivaNova, fostering an ethical culture is very important. Raising concerns not only protects our company but also our customers, patients, and each other. By being open and candid about our concerns, we set an example for others to Speak Up, creating a safe environment for everyone.
 
If you suspect a violation of the Code of Ethics & Business Conduct, our policies, or the law, you have an obligation to promptly raise a concern. When in doubt, always Speak Up.
 
Our Speak Up Program includes a 24/7 Ethics Helpline, available to employees and third parties for confidential and anonymous reporting via web, email, or phone, in multiple languages.
 
All leaders must ensure a safe space for employees to raise concerns without fear of retaliation. Any concerns about potential violations should be immediately escalated to the Ethics Helpline, Compliance, or Human Resources.
 
As described in both our Code of Conduct and Speak Up and Non-Retaliation Policy, everyone at LivaNova has a responsibility to promptly report any violation of the Company’s Code of Conduct, Policies, Procedures, laws impacting Company business, or any other potentially unethical conduct to Compliance, or report confidently at https://livanova.ethicspoint.com.
 
Once a report is received, the Head of Global Investigations (or their delegate) classifies, triages, and assigns the report to an investigator for investigation.  Ethics Helpline metrics and Critical cases are reported quarterly by the Chief Compliance Officer to the Compliance Committee and to the Audit Committee of the LivaNova Board of Directors. 
 
LivaNova has a strict non-retaliation policy and does not tolerate any form of retaliation against individuals who, in good faith, report potential violations or participate in investigations. Whistleblower rights and remedies are protected under applicable laws. This policy applies even if an allegation made in good faith is ultimately unsubstantiated.
 
For German / Italian employees, please refer to local Speak Up policies for more information.

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 suppliers, distributors, agents, product resellers, vendors, consultants, contingent workers, and other business partners (“Third Parties”) who share our commitment to operating in a responsible and ethical manner.

Accordingly, this Third Party Code of Conduct outlines the standards and expectations for ethical and sustainable business conduct of LivaNova Third Parties, and their subsidiaries, subcontractors, affiliates, employees, and agents (“Representatives”). It covers areas such as human rights and labor conditions, the environment, quality, and confidentiality and data privacy.

LivaNova is committed to the highest ethical standards and compliance with laws and regulations applicable to our business, including laws related to slavery and human trafficking.

This statement sets out the Company's commitment towards these efforts for the 2021 fiscal year.

As part of our initiative to identify and mitigate risks relating to modern slavery, LivaNova has taken the steps described further in this statement and is continuously working to further improve our policies and practices to ensure: 1) materials and services provided to LivaNova are procured only from suppliers who share our same level of commitment, and 2) modern slavery does not exist within our own business operations.

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.

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 Code of Conduct and ethics & compliance policies, are the foundation of LivaNova's ethics and compliance program.

At LivaNova, our priority is to improve the lives of patients with our products and therapies. Without the help of our valued partners in the healthcare field, we would not be able to achieve this goal.

To build and maintain trust between the medical device industry, the healthcare players, and 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.

Confindustria Dispositivi Medici, an Italian medical association, requests that its members 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.

LivaNova shall publish the transfers of value made each year within the first six months of the following year.

For more information about the LivaNova Transparency Program, please email AskEI@livanova.com.