Centinel Spine, LLC desires to ensure that its operations continue to be conducted in
accordance with all national, state and local laws and regulations. To underscore and enhance our commitment to ethical behavior in all
that we do, we have implemented a Corporate Compliance Program. Our Corporate Compliance Program is intended to establish a framework for
legal compliance by the company and our personnel.
We strive to provide surgeons with the products, services and information they need to provide the best for
their patients. We have established a reputation of trust that must be preserved and strengthened. We are committed to fostering an environment
that encourages all Centinel Spine, LLC. personnel to actively participate in accomplishing effective compliance with all laws and regulations.
We are proud to demonstrate our commitment to following all legal requirements and ethical principles in providing our products and services.
Centinel Spine, LLC has been, and continues to be, committed to conducting its business in full compliance with
all national, state and local laws and regulations. We are particularly committed to preventing, detecting and resolving non-compliance with these
requirements. The Corporate Compliance Program aids Centinel Spine in this prevention, detection and resolution. We require that all compliance
issues encountered be raised, thoroughly investigated and resolved in a timely manner in accordance with this Compliance Program. The Compliance
Program is designed to assist Centinel Spine in protecting the excellent reputation and high levels of trust that we have established in the market.
Please contact our Compliance Officer, Rick Reed at firstname.lastname@example.org
or by telephone at (610) 999-7755 with any questions or concerns.
Centinel Spine, LLC has an obligation to collect and report payments and transfers of value made to physicians
in accordance with the provisions of the Physician Payment Sunshine Act beginning August 1, 2013. Transfers of value related to events will be recorded and
Declaration of Adoption of Comprehensive Compliance Program Pursuant to California Health and Safety Code
Centinel Spine designs, manufactures and sells orthopedic medical devices. As a medical device manufacturer with a
strong commitment to ethical behavior, Centinel Spine has adopted a Comprehensive Compliance Program in accordance with the Compliance Program
Guidance developed by the United States Department of Health and Human Services Office of Inspector General.
This Comprehensive Compliance Program includes written standards, employee training, an anonymous hotline, monitoring, a Code of Business Conduct,
dedicated compliance office leadership and other elements of an effective program. As an organization we strive to conduct all of our business
interactions with healthcare professionals in a compliant and ethical manner.
Our Code of Conduct sets out the expectation of behavior expected of all employees and specific sections of the Code of Conduct summarize
Centinel Spine policies regarding interactions with medical or health care professionals.
Centinel Spine has adopted a Compliance Policy for interactions with health care professionals which is based on the Advanced Medical Technology
Association Code of Ethics on Interactions with Health Care Professionals (the “AdvaMed Code”; effective July 1, 2009), and which regulates the
Company’s interactions with health care professionals. Centinel Spine has supplemented the AdvaMed Code with certain provisions necessary to comply
with state laws governing these interactions as appropriate.
Our policies on interacting with Healthcare Professionals establishes explicit limits on meals, promotional materials or items or activities that
Centinel Spine or its representatives may give or otherwise provide to an individual medical or health care professional ($2,000 per surgeon annual limit).
To the best of our knowledge, Centinel Spine is in all material respects in compliance with a Comprehensive Compliance Program (“CCP”) that satisfies
the requirements of California Health and Safety Code §§ 119400-119402, based on our good faith understanding of the statutory provisions as they may
apply to a medical device manufacturer.
Questions on the Code of Conduct, our Comprehensive Compliance Program, requests for materials or any addition questions can be directed to our
Compliance Officer at (860) 904-4451. – Updated as of February 11, 2015.