CODE OF CONDUCT
TMC’s corporate mission, “Contributing to Society through Healthcare,” is the collective goal of the company and its Associates. To meet this goal, we established a Code of Conduct to set the standards that govern our daily business activities in the U.S. as well as overseas. In accordance with this Code, TMC engages in honest and fair business practices, strives for compliance with all relevant laws and regulations, and acts in accordance with heightened business and social ethics.
The Terumo Code of Conduct states that “Each Associate must conduct business activities honestly, act in a manner that demonstrates responsibility for environmental conservation and seek to become a model citizen within the corporate group.” We provide training on the Code of Conduct tailored to each business site and instill in our Associates the importance of acting ethically. As a global company, our Code of Conduct clearly states and promotes the need to respect human rights and eliminate discrimination.
TMC CORPORATE COMPLIANCE PROGRAM
To ensure our actions reflect our commitment to the highest ethical and legal standards, fulfill our corporate mission and adhere to our Code of Conduct, TMC has developed a comprehensive Compliance Program. Designed to address existing and emerging business, legal and social challenges, the Compliance Program includes the following critical components:
- Oversight by a hierarchy of individuals and entities with clear objectives and responsibilities, including a designated Compliance Officer, an Ethics and Business Compliance Committee with representation from multiple company departments, and several subcommittees to ensure compliance within specific company operations, such as interactions with Health Care Professionals, research and educational grants and advertisement and promotions.
- The designated Compliance Officer for TMC is Alessandra Spina, Associate General Counsel - Healthcare Compliance.
- Identification of specific corporate, ethical, social and business risks and the development of clear and comprehensive policies regarding each.
- A comprehensive training program to empower Associates with the knowledge necessary to carry out their roles in full compliance with company policies, and the laws, regulations and standards they are based upon.
- Multiple pathways for Associates to report compliance violations and raise questions or concerns in a manner that maintains the respect and comfort level of the reporting individual while ensuring their issues are addressed in a timely and satisfactory manner.
- Ongoing monitoring and review of the Compliance Program as well as developments in the law and industry to ensure the program recognizes and addresses new and emerging risks and presents every opportunity for Associates to fully engage as good corporate citizens.
- TMC does not tolerate any form of retaliation against an individual who either: (1) reports in good-faith a potential violation of Terumo’s policies, federal or state laws, rules, or regulations; or (2) participates in an investigation of any such report.
TMC COMMITMENT TO TRANSPARENCY
TMC values its relationships with Health Care Professionals (HCPs) and respects the contributions that their independent judgment brings to TMC’s business. The candid input of experienced HCPs allows TMC to continually improve upon the safety and effectiveness of its products, and to develop innovative and less invasive devices for the patients that need them. All TMC’s interactions with HCPs are intended to benefit patients and enhance the practice of medicine.
TMC is committed to full transparency in its relationships with HCPs, and adheres to a strict code of ethics governing the openness of these collaborations as described below:
- AdvaMed Code of Ethics on Interactions with Health Care Professionals – AdvaMed is a trade association that leads the effort to advance medical technology through the highest ethical standards and to facilitate timely patient access to safe and effective products. It furthers this mission through the development of standards and codes of conduct to assist medical technology companies in their business interactions, including a Code of Ethics that governs the relationships between medical device companies and HCPs. TMC has adopted the AdvaMed Code of Ethics, which can be viewed here: AdvaMed Code of Ethics
TMC also reports information about its interactions with HCPs in accordance with federal and state laws so the information is available for public review:
- U.S. Physician Payments Sunshine Act – Through the Sunshine Act, also known as the Open Payments Act, TMC reports annually to the Centers for Medicare and Medicaid Services (CMS) any payments or other transfers of value it made to physicians or teaching hospitals. Maintained by CMS, the data is available for review by the general public as well as by the physicians and teaching hospitals reported. https://www.cms.gov/openpayments/
- State Sunshine and Open Payments Acts – TMC also provides data on an annual basis to states that collect information regarding interactions with HCPs that practice in their jurisdictions, including Vermont and Massachusetts. These states also make the data collected available to the public on their respective websites.
Interactions with or transfers of value to HCPs that are reported to CMS and/or the states include:
- Compensation paid to health care professionals for services performed for TMC
- Educational items (medical text books, scientific journal articles)
- Food, beverage, travel, and lodging relating to consulting services, product training, and other business related activities
- Education on the use of TMC products
- Research on new products to help advance patient care
- Charitable contributions
- Royalties or license payments
- Grants to support healthcare education
- Rental or facility fees associated with product training, clinical studies or exhibit space
TMC COMPLIANCE REPORTING INTEGRITY HOTLINE AND WEBSITE
TMC encourages Associates to raise concerns related to workplace integrity and has adopted a program to ensure they feel comfortable asking questions and reporting misconduct. Associates can at any time approach their Manager, their Manager’s Manager, the Human Resources Department or the Legal and Compliance Department. In addition, if an Associate is uncomfortable with any of these reporting pathways or prefers to remain anonymous, they can access the Integrity Compliance Hotline or the Integrity Compliance Website.
Associates can call the toll-free Hotline number 24/7, every day of the year. The phone line is independently managed by a third-party vendor, supports multiple languages and provides professional operators to help employees describe their concerns. The calls are confidential and the caller can choose to remain anonymous and not to disclose their personal information. Associates may also report their concerns online through a designated website, also hosted and managed by a professional third-party vendor. As with the Hotline, reports submitted through the website will be kept confidential and Associates can choose to remain anonymous.
The Integrity Hotline can be accessed at: 1-800-261-9347 (U.S.), 1-800-205-6545 (Canada) or 1-800-210-8757 (Puerto Rico)
The Integrity Website can be accessed at: www.terumointegrity.com