COOPERVISION - DECLARATION OF COMPLIANCE WITH COMPREHENSIVE COMPLIANCE POLICY
As part of CooperVision, Inc.’s ongoing efforts in the area of compliance, we have developed and implemented a Comprehensive Compliance Program that is designed to comply with applicable federal and state laws as well as industry standards relating to the marketing and promotion of our products to healthcare professionals. To our knowledge, as of the date of this declaration, CooperVision, Inc. (“CooperVision”) is in material compliance with its Comprehensive Compliance Policy, as described here as it pertains to California health care professionals, and, should it apply, with California Health & Safety Code, Sections 119400-119402.
CooperVision has established a program designed to help ensure: (1) ethical interactions with health care providers; and (2) promotion and marketing practices that are in compliance in material respects with applicable federal and state laws and industry standards, such as the Code of Ethics on Interactions with Health Care Professionals, published by the Advanced Medical Technology Association ("AdvaMed").
II. MEETINGS AND SALES AND PROMOTIONAL MEETINGS
CooperVision will not, with limited exceptions that are in accordance with nationally recognized standards, reimburse for travel and lodging expenses of attendees at third party educational conferences. CooperVision may reimburse attendees for their reasonable travel and lodging expenses, and provide modest hospitality, associated with attendance at meetings focused on the education and training in the safe and effective use of CooperVision products and/or in the sale and promotion of CooperVision products involving matters such as product features and sales terms. These meetings are conducted in locations intended to be conducive to the exchange of information such as customer facilities, conference settings or company facilities. CooperVision will not pay for lodging or travel for guests or spouses of attendees.
III. BUSINESS MEALS AND HOSPITALITY
CooperVision may occasionally offer a modest meal and/or reception, typically as part of an educational or product training meeting. These educational or product training meetings do not include entertainment or recreation, and a representative of CooperVision is present for the duration of the meeting. Where possible, these meetings will be held on the health care professional’s premises or other location reasonable and conducive for the educational or product training purpose.
IV. PROVISION OF EDUCATIONAL AND PROMOTIONAL ITEMS
On occasion, CooperVision representatives may provide patient or practice related items. These items will be of reasonable value (generally less than $100 retail value per item) and not capable of non-educational use. Gifts of promotional or "reminder" items of nominal value, such as pens, coffee mugs and gift cards, are no longer permitted under CooperVision's policy.
V. ACTING COMPLIANCE OFFICER
CooperVision's Director of Customer Service, USA, Mary Petromallo, acts as Compliance Officer for purposes of this compliance program. Our Compliance Officer has been empowered with appropriate authority to exercise independent judgment and has free and unencumbered access to senior management.
VI. EMPLOYEE TRAINING
An important element of CooperVision's Comprehensive Compliance Policy is the education and training of our employees on their legal and ethical obligations under applicable healthcare programs. CooperVision is committed to taking necessary steps to effectively communicate our standards and procedures to affected personnel.
CooperVision encourages dialogue between management and employees. Our goal is that all employees, when seeking answers to questions or reporting potential instances of legal violations, should know to whom to turn for a meaningful response and should be able to do so without fear of retaliation. Employees are expected to report suspected violations of company policy by contacting the Compliance Officer. Employees may also report potential violations to their manager or to Human Resources.
VII. AUDITING AND MONITORING
CooperVision's Comprehensive Compliance Policy includes ongoing efforts to monitor, audit, and evaluate adherence to its compliance activities. The nature of our reviews as well as the extent and frequency of our compliance monitoring, auditing, and evaluation varies according to a variety of factors, including new regulatory requirements, changes in business practices, and other considerations.
VIII. ENFORCEMENT AND INVESTIGATION
CooperVision's Comprehensive Compliance Policy strives to ensure that the consequences of violating the law or company policy are clearly understood by its employees and that appropriate, consistent disciplinary action is enforced. Our Comprehensive Compliance Policy requires the company to evaluate each case and respond promptly to potential violations of law or company policy, take appropriate disciplinary action, assess whether the violation is in part due to gaps in our policies, practices, or internal controls, and take action to prevent future violations.
[August 1, 2018]