Compliance

• Code of Conduct
• Sales and Marketing Code of Conduct
• Compliance Hotline
• Patient Privacy Compliance
• Health Care Compliance
• Product Compliance
• Accounting and Finance Compliance

DJO Confidential Compliance Hotline

As part of DJO’s commitment to transparency regarding laws and regulations and to maintain a safe and secure workplace, the Company has established a hotline for individuals to report illegal, unethical or unsafe situations. The hotline provides an anonymous method, if the individuals so chooses, to report any instances of misconduct regarding the Company’s finances or other business situations. Furthermore, the Company prohibits retaliation against any employee who, in good faith, reports a violation. The DJO confidential compliance hotline is 1-877-888-0002.

Patient Privacy Compliance

DJO complies with Federal laws regarding the privacy of health information that identifies or that could be used to identify patients. We understand the importance of safeguarding all medical information and are firmly committed to protecting the privacy of the patients we serve. Towards that end, DJO employees are carefully trained to protect patient privacy and promote a corporate culture of respect for the confidential patient information in our possession.

Click here to view the DJO Notice of Privacy Practices.

Health Care Compliance

The DJO Compliance and Ethics Program addresses the portion of the Company that functions as a Durable Medical Equipment, Prosthetics, Orthotics, and Supplies ("DMEPOS") Supplier, and incorporates the seven elements recommended by the Department of Health and Human Services Office of the Inspector General. In its role as a DMEPOS Supplier, DJO is proud to be accredited by the Accreditation Commission for Health Care ("ACHC"). The DJO Compliance and Ethics Program also addresses the numerous requirements imposed upon a Medical Device Company regarding relationships with Health Care Professionals and the laws pertaining to transparency of these relationships. DJO is an AdvaMed member and strongly supports and abides by the AdvaMed Code of Conduct. The DJO Sales and Marketing Code of Conduct was developed specifically to provide guidance to the DJO sales and marketing teams of the Company’s expectations in this important arena.

Click here for an overview of the elements of the DJO Health Care Compliance Program

Product Compliance

As a world-wide provider of medical devices based in the United States, DJO designs, manufactures and distributes our products in accordance with Title 21 of the Code of Federal Regulations, Subpart 820, Quality System Regulation of the U.S. Food and Drug Administration. DJO’s Quality Management System is also harmonized with global medical device regulations and internationally recognized quality standards in order to meet or exceed the expectations of our customers and maintain compliance with all applicable regulatory requirements. Accordingly, our Quality Management System is certified for compliance to ISO 13485:2003, the European Council (EC) Directive 93/42/EEC and the Canadian Medical Device Regulations. In order to ensure continued compliance, our design and manufacturing facilities are subject to audit once every two years by the US Food and Drug Administration, annually by an independent third-party quality system Registrar and periodically by trained, internal DJO auditors.

Accounting and Finance Compliance

The senior Accounting and Finance leadership team oversees the application of critical accounting policies and analyzes financial metrics to monitor the strategic direction of the Company. The team regularly discusses the application of controllership metrics as well as new or upcoming accounting policies. DJO adheres to a rigorous set of accounting policies and devotes significant resources to ensuring that those policies are applied properly and consistently throughout the organization.

DJO management reviews the financial operating results and associated metrics with the Audit Committee of the Board of Directors. In addition, the Company has an established global Internal Audit function, which reports directly to the Audit Committee of the Board of Directors and executive management. The Audit Committee reviews the outcome of internal audits and the Sarbanes-Oxley Section 404 Internal Control Certification.

The Company maintains a dynamic system of Internal Control designed to ensure reliable financial reporting and the safeguarding of assets. The Company's continued commitment to internal control enabled the Company to complete the evaluation of internal controls over financial reporting that is required by Section 404 of the Sarbanes-Oxley Act.

DJO Global, Inc. requires all of its directors, officers and employees to observe high standards of integrity and honesty, and to act with care, diligence and fairness in all business activities. Interactions with all stakeholders and wider society should be conducted in an ethical and legal manner.

AdvaMed Code of Ethics