Promotion and Interaction with Healthcare Providers
Maquet and Atrium (“Maquet”) recognizes that adherence to ethical standards and compliance with applicable laws, regulations and the 2009 AdvaMed Code of Ethics are critical to ensure that our product promotion and interactions with Healthcare Providers (HCPs) in the United States are responsible and within legal and regulatory requirements. All employees who may be expected to interface with Healthcare Providers are required to receive training regularly and conduct themselves in accordance with the Maquet U.S. Healthcare Compliance Plan, which can be found at http://www.maquet.com/compliance. The Compliance Plan also applies to all U.S. based Maquet Employees working outside of the U.S. on applicable U.S. related Maquet business. The Compliance Plan provides detailed guidance as to what is and is not acceptable in your interactions with HCPs, including:
- Discussion of our products
- Discounts and rebates
- Entertainment and recreation
- Grants or other payments
- Consultancies and speaking arrangements
- Clinical trials and other research endeavors
- Provision of samples, evaluation products and demonstration products
- Continuing Medical Education (CME) and training
- HCP payment reporting
HCPs include people or entities in a position to purchase, lease, recommend, use or arrange for the purchase or lease of Maquet products. This includes both clinical and non-clinical personnel who affect decisions related to product purchase. It also includes decision-makers within group purchasing organizations.
Should you become aware of any violations of the Compliance Policy such as an outright bribe or a questionable gift to a healthcare provider, you must report the incident to your supervisor, who will communicate your concerns to the Maquet Compliance Counsel. Credible and verifiable Compliance Plan violations will be addressed vigorously and will result in appropriate action, including corrective action, up to and including termination.
Maquet encourages you to communicate concerns regarding any inappropriate or illegal behavior to your immediate supervisor or your supervisor’s manager. If you are not able to report your concern to your immediate management, we also encourage you to discuss your concerns with the Human Resources department, or contact the HR Helpline at 973-709-7878 or email HRHELPLINE@maquet.com. However, we recognize that there may be times, due to the serious nature of the concern, that you may decide to report the concern to our Compliance Hotline at 1-800-247-1656 or site https://Reportlineweb.com/GetingeHoldingsUSA.
Reporting to the Compliance Hotline and Website is anonymous. However, as you may expect, investigations based on an anonymous report are more difficult than those based on an in-person report where we can have a continuous dialogue. Thus, to facilitate our investigations, we encourage you to report in person. If you must use the Compliance Hotline or Website, we encourage you to provide your name and contact information. We will ensure no retaliation occurs against employees who report truthfully and in good faith.
Please reach out to the Maquet Compliance Department at UScompliance@maquet.com with any questions regarding the Compliance Plan or other Compliance-related issues.