Advanced Bionics, LLC (“AB”), a subsidiary of Sonova Holdings AG (“Sonova”), 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 ethical standards and compliance with all applicable laws and regulations as we continue to strive to achieve the highest standards of conduct.
AB’s Corporate Integrity Program (the “Program”) embeds the Sonova’s Code of Conduct and additional group wide policies in the AB organization. The Program is administered by AB’s Compliance Manager, who reports to Sonova’s Head of Group Compliance as well as AB’s President. The Compliance Manager coordinates the AB Compliance Committee, which consists of AB’s President as well as divisional and functional leaders, which may from time to time decide to update elements of the Program. Minor updates may be made by the Compliance Manager directly, but will be brought to the attention of the Compliance Committee.
The Program specifically addresses areas that may be susceptible to unlawful behavior within the context of our business dealings. Integrity, in the broadest sense, must govern our actions in all of our relationships with patients, health care providers, vendors and all business partners. Integrity is also what we expect to govern the relationship between our employees. It is every employee’s responsibility to stay up to date with the Program and any published updates. Regular trainings are made available to all employees.
AB encourages all employees to lead by example and to report any concerns about inappropriate or unethical behavior. Employees can address these to their supervisor, senior management, the Compliance Manager, contact the toll-free Compliance Hotline (1-866-447-5045) or use the email address email@example.com.
AB will not retaliate nor tolerate any retaliation against any employee for reports made in good faith.
By working together with integrity, we can achieve our goals — to improve lives by developing technologies and services that help the recipients of our medical technology to achieve their full potential.
Sr. Compliance Manager
Consistent with the principles embraced by the Sonova Group (“Sonova”), AB is committed to conducting its operations ethically and in compliance with all applicable laws, rules, and regulations. To support this commitment, AB has implemented and endorses the Sonova Code of Conduct to provide guidance on employee and organizational ethical values.
This is a summary of AB’s Corporate Integrity Program (the “Program”). It is complemented by the global Sonova Code of Conduct, as well as group wide policies and procedures. Our Program is dynamic and evolves as California and other relevant state and federal laws and regulations and industry best practices progress.
As noted in the U.S. Department of Health and Human Services’ April 2003 publication “OIG Compliance Program Guidance for Pharmaceutical Manufacturers” (the “OIG Guidance”) the Statute applies to the pharmaceutical industry, however, a footnote in the OIG Guidance indicated application to manufacturers in medical device industry. Consistent with the OIG Guidance, AB has adopted a compliance program taking account of the nature of our business as a medical device manufacturer.
The Program embeds the Sonova’s Code of Conduct and additional group wide policies in the AB organization, which includes the following:
As of the date of this declaration to the best of our knowledge, Advanced Bionics, LLC is in compliance with the provisions of the California Health and Safety Code § 119402 in all material respects.
To obtain a copy of the compliance program and/or the annual written declaration, please call 1-800-440-6436 or email firstname.lastname@example.org.
Last update: October 1, 2019
AB LLC Corporate Integrity Program, October 2019 (version 3)