Comprehensive Compliance Program and California Declaration of Compliance

Advanced Bionics, LLC (“AB”) is committed to ethics, integrity, and accountability as these are at the center of the organization’s core values. All of us at AB are responsible for adhering to the highest ethical standards and compliance with all applicable laws and regulations. AB has established a Comprehensive Compliance Program (“Program”) for its United States (“U.S.”) operations, which reflects AB’s commitment to compliance with the laws and regulations that govern the marketing, sale, and distribution of medical devices and accessories in the U.S. AB’s Program is set forth in AB’s Corporate Compliance Policy Booklet, which is based on the Sonova Code of Conduct.

AB’s Program seeks to prevent and detect violations of U.S. law and company policies and procedures, and is modified, as necessary, to account for changes in applicable U.S. laws and regulations. The Program sets forth applicable written standards for appropriate conduct, reflects our commitment to continually train and communicate with employees regarding compliance, and has systems in place to prevent, detect and remedy potentially improper conduct. The AB Program specifically addresses areas of risk of improper or illegal conduct within the context of our business. In addition, AB’s Program includes specific dollar limits on items that AB may provide to healthcare professionals based in California, such as meals, travel and educational items

As of the date of this declaration, AB in good faith believes that its U.S. operations are in compliance with its Program and applicable requirements of Sections 119400-119402 of the California Health & Safety Code. This declaration is made solely for the purpose of complying with the California law cited above and should not be read in isolation from current or future documents or discussions related to the Program.

Anyone who would like to obtain written copies of the Sonova Code of Conduct, the AB Corporate Compliance Booklet and this declaration can do so by contacting AB at 866-844-4327.

April 2023