Comprehensive Compliance Program

At Arjo, we believe that empowering movement within healthcare environments is essential to quality care. Our products and solutions are designed to promote a safe and dignified patient experience. We are committed to driving healthier outcomes for people facing mobility challenges.

Compliance is an integral part of how Arjo conducts business and interacts with employees, customers and business partners. Arjo Inc. established its Comprehensive Compliance Program (CCP) to materially comply with applicable federal and state laws, as well as industry standards. The CCP contains the elements of an effective compliance program as outlined in guidance published by the Office of the Inspector General, U.S. Department of Health and Human Services.

Overview

1. Leadership and Structure

Arjo Inc.’s Director of Business Compliance is charged with developing, operating and monitoring the compliance program. The Director of Business Compliance interacts routinely with senior management.

The Director of Business Compliance works on the advice and under the supervision of the Business Compliance Committee. The Committee is comprised of Arjo Inc. senior management and meets on a regular basis.

2. Written Standards

Arjo Inc. demonstrates its commitment to compliance through its implementation of policies, including the Code of Conduct. Arjo Inc.’s Marketing Code of Conduct includes the Code of Ethics on Interactions with Health Care Professionals adopted by the Advanced Medical Technology Association (AdvaMed).

Arjo Inc. established a total annual spending limit on meals and gifts that may be provided to individual California Healthcare Providers of an aggregate of $1,500, pursuant to Cal. Health & Safety Code §§ 119400-119402 (S.B. 1765). This limit does not apply to samples provided in conjunction with product trials or fees for services.

3. Education and Training

Arjo Inc. provides regular compliance training to all US employees, including at hiring. Employees receive training on Arjo policies and all applicable laws and regulations.

4. Internal Lines of Communication

Arjo Inc. uses a variety of tools to communicate with employees about compliance issues and concerns. These include an internal website and employee meetings. We instruct employees on their obligation to report their compliance concerns through their managers, Human Resources or Business Compliance. Arjo Inc. also employs independent, third-party vendors where employees may make anonymous online or telephone reports of concerns.

5. Auditing and Monitoring

The CCP includes monitoring and auditing to evaluate compliance with federal and state laws and regulations, as well as Arjo policies and procedures. Auditing and monitoring is targeted based on annual risk assessments, new regulatory requirements and changes in business practices. Identified issues and opportunities for enhancement are addressed.

6. Responding to Potential Violations

Arjo Inc. responds promptly to potential violations of law, regulations or Arjo policies. Arjo Inc. takes potential compliance concerns seriously and investigates concerns thoroughly.

7. Corrective Action Plans

After investigation of potential compliance concerns corrective action plans to address the concerns are designed, implemented and monitored. Corrective action plans may include new policies and procedures, additional training and when necessary, disciplinary action.

Declaration

Arjo Inc. declares that as of June 1, 2023, and to the best of its knowledge, it is in compliance with this Comprehensive Compliance Plan.

Copies of the CCP may be requested by calling 1-800-323-1245.