Micrus Endovascular
Comprehensive Compliance Program
Micrus
Endovascular (“Micrus”) is committed to conduct its business in accordance
with high ethical standards. Micrus maintains Company Operating Policies
which define the Micrus Code of Conduct.
Micrus has adopted a Comprehensive Compliance Program (“CCP”) applicable
to all Micrus officers, employees, contractors and agents
in their interactions with organizations and healthcare professionals
serving
1. Core Objectives.
A. The Core Objectives of this CCP are to:
(1) Directly improve care of patients;
(2) Direct Micrus’ philanthropic resources to programs controlled by independent and highly regarded educational, academic and clinical organizations;
(3) Reinforce Micrus’ standing as a good corporate citizen;
(4) Prevent the improper impact of gratuities or courtesies on healthcare professionals, such as to interfere with scientific decision-making or to induce business with Micrus; and
(5) Ensure full compliance with all applicable laws and regulations.
2. Compliance.
A. Office of Compliance. To provide guidance and assistance with compliance of this CCP, Micrus has established the position of the Corporate Compliance Officer (the “CCO”). The CCO shall perform the following functions:
(1)
Provide a centralized point of contact where all officers, employees, contractors
and agents of Micrus can anonymously communicate instances of misconduct
or noncompliance with the CCP;
(2) Ensure that all Micrus professional relationships with healthcare professionals comply with applicable ethical and professional standards and laws; and
(3) Provide a mechanism for audit, investigation and recommendations for resolution (and discipline where appropriate) in the cases of non-compliance with Micrus’ CCP.
B. Education and Training. Micrus maintains Company Operating Policies which define the Micrus’ Code of Conduct, appropriate funding support, and control, documentation and approval mechanisms related to such funding support. Such policies, as well as the guidelines set forth in this CCP, shall be provided to all personnel with marketing duties or who interact with healthcare professionals in their job functions. In addition, periodic training programs will be offered to further communicate and reinforce the Core Objectives set forth above.
C.
Distribution of Compliance Program. A copy of this CCP is available upon written
request of any individual (addressed to the Micrus Headquarters).
D.
Reporting. Each year Micrus will publish an annual certification of
compliance with this CCP for the prior year.
3. Program Funding. Donations and financial support of any entity by Micrus constitutes a significant area of risk for the noncompliance or the appearance of noncompliance with respect to the Core Objectives. To mitigate such risk, no financial support will be provided by Micrus to healthcare professionals if such support would adversely impact the independence of prescribing practices in support of any specific product. It is Micrus’ policy and practice that it shall never forgo business integrity and ethics for the purpose of achieving or retaining revenues. Any funding activities provided by Micrus to or for the benefit of healthcare professionals shall be reasonable, customary and occasional in nature, will be reflected on Micrus’ books in the ordinary course, and will only be provided after an appropriate review and approval.
4. Individual Healthcare Professionals. Gifts and economic benefits provided to the healthcare professionals entail risk, and Micrus’ Code of Conduct contains controls and mechanisms to avoid even the appearance of impropriety. Except for those few arrangements permissible under federal or state laws, Micrus will limit its total annual promotional benefits to any individual healthcare to $500. Micrus anticipates that the annual promotional benefits to individuals, such as educational and office-related items, will in most cases fall considerably below this annual limit, and Micrus commits that these occasional benefits will in all cases be of a not substantial value.