Code of Conduct for Business Partners


INTEGRA CODE OF CONDUCT FOR BUSINESS PARTNERS

The following Code of Conduct for Business Partners (the “Code of Conduct”) applies to all individuals and organizations that are Suppliers to or Third- Party Intermediaries1 for Integra (“Business Partners”). This Code of Conduct sets minimum requirements and expectations for the conduct of Integra’s Business Partners; however, Integra encourages our partners to establish stricter or more extensive requirements where appropriate. Additionally, this Code of Conduct supplements, but does not supersede, any right of Integra established under an agreement between Integra and its Business Partner. Integra reserves the right to reasonably change the requirements of this Code of Conduct due to changes in applicable laws, regulations, and Integra’s compliance program. In such event, Integra expects Business Partners to accept such reasonable changes.

EACH BUSINESS PARTNER AGREES TO ADHERE TO THE FOLLOWING BASIC PRINCIPLES:
1. COMPLIANCE WITH LAWS AND REGULATIONS

  • Business Partners must comply with all applicable laws, rules, regulations, and ethical standards in the industry and country in which they operate.

2. PROHIBITION OF CORRUPTION AND BRIBERY

  • Business Partners must comply with the U.S. Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act, and the anti-money laundering laws of the countries in which Integra operates. Integra does not allow any bribes or improper payments, including kickbacks, unexplained or undocumented rebates, payment for advertising, or gifts disguised as allowances or expenses.

3. CONFIDENTIALITY, DATA PRIVACY, AND INTELLECTUAL PROPERTY RIGHTS

  • Business Partners are expected to protect Integra proprietary and confidential information. Business Partners requiring an exchange of such information with Integra are required to execute a confidentiality agreement in advance.
  • Business Partners must comply with all applicable data privacy laws and regulations when handling personal information. Business Partners are expected to immediately report any unauthorized use, disclosure, or loss of Integra proprietary and confidential information or personal information.
  • Business Partners shall respect intellectual property rights and confidential information belonging to third parties and must not infringe upon the intellectual property rights of others.

4. FAIR COMPETITION AND ANTI-TRUST LAWS

  • Business Partners must act in accordance with all applicable national and international laws and regulations regarding fair competition and anti-trust, and shall not participate in price fixing, market or customer allocation, market sharing, or bid rigging with competitors.
  • Business Partners must not misrepresent Integra Products, act dishonestly, or participate or engage in any anti-competitive or unfair practices.

5. SOCIAL RESPONSIBILITY, HUMAN RIGHTS, AND LABOR

  • Integra expects Business Partners to treat their employees and Integra's employees with respect and maintain a healthy and safe workplace free from harassment, discrimination, intimidation, and retaliation. Business Partners must comply with all applicable employment laws and regulations, including, but not limited to, statutes that prohibit discrimination in the workplace.
  • Integra will not tolerate any forms of slavery, servitude, forced labor and human trafficking, and Business Partners must not engage in any practice that constitutes any form of modern slavery.
  • Business Partners must maintain labor standards including conditions, wages, and overtime wage practices that comply with the laws in the locations in which they operate. Business Partners must not require their employees to exceed maximum hours of work prescribed by law.
  • Business Partners must maintain a workplace that is free from discrimination and harassment based on race, color, creed, religion, sex, age, disability, national origin, ancestry, citizenship, marital status, veteran status, sexual orientation, gender identity or expression, or any other status protected under applicable laws.

6. CONFLICTS OF INTEREST

  • Business Partners shall avoid all conflicts of interest that may adversely affect business relationships.
  • If a Business Partner is aware of any conflicts of interest, the business partner should disclose these to Integra.

7. FRAUD

  • Integra has zero tolerance of an prohibits fraud, which is the act or intent of cheating, deceiving, misrepresenting, or lying for any personal or professional advantage.
  • Business Partners must not engage in any fraudulent behavior including, but not limited to:
    • Theft of Integra funds of property
    • Misusing Integra resources for private purposes
    • Misrepresenting or concealing transactions
    • Forging or altering documentation
    • Intentionally filing false financial records or statements
  • Business Partners must keep accurate accounts and records and should:
    • Comply with generally accepted accounting principles, and all relevant laws and regulations
    • Maintain books, expense reports, and receipts that honestly reflect financial transactions
    • Record all business transactions completely, accurately, in the proper period, and in a timely manner

8. ENVIRONMENT, HEALTH & SAFETY

  • Business Partners must comply with all applicable laws, regulations, and standards regarding environment, health and safety.
  • Business Partners that work with Integra at any of its locations must comply with applicable Integra and local environmental, health and safety requirements. Any Business Partners on site must ensure their own safety and that of others. Any emergency that may impact Integra and/or its environment, health or safety must promptly be reported.

Resource: https://www.integralife.com/esg-report

9. OTHER GOVERNMENT REGULATIONS

Please refer to our external webpage: https://www.integralife.com/csrcompliance.

10. DEALINGS WITH THIRD PARTIES

Business Partners shall make reasonable efforts among their own customers, suppliers, and third-party intermediaries to comply with this Code of Conduct.

11. COOPERATION

Before a business partner qualifies as a partner with Integra, they need to complete the following steps as deemed appropriate by the Compliance Department:

- Complete a Due Diligence Questionnaire and provide accurate and complete information
- Address any questions that arise during the due diligence review
- Complete training on the anti-corruption principles Contracts will be initiated once all steps in the due diligence process are complete.

Contracts will be initiated once all steps in the due diligence process are complete.

12. SPEAK UP AND REPORT ANY VIOLATIONS

Business partners should report any violations they are aware of. If a Business Partner sees something inappropriate or unethical, or if a Business Partner witnesses anything that goes against Integra Code values, Integra encourages them to speak up. The Business Partner may ask questions, seek guidance, or report concerns through the Integra Ethics Hotline.

Within the US

To report a compliance concern in the US, use one of the following:

  • The Integra intranet site
  • Public Internet:
  • Toll-Free Phone:
    • Call 1-888-279-6256
    • Someone will assist you

Outside the US

To report a compliance concern outside the US, use one of the following:

REPORTING A CONCERN

When reporting a concern, you should include as much information as you can. At a minimum, be sure to include:

  • Who: persons engaged in the incident, including titles
  • What: what specifically occurred
  • Where: the location of the incident
  • When: the time and duration of the incident

Note: The Integra Ethics Hotline is a confidential resource that is available 24 hours a day, 7 days a week, 365 days a year. The hotline is operated by an independent company.

 

For other questions or concerns, contact your local business representative.

 

For additional resources and guidance on this Code of Conduct, please visit www.integralife.com. Any concerns relating to adherence to this Code may be reported to Integra's Chief Compliance Officer.

 

1. Third-Party Intermediaries' include distributors, sub-distributors, sales agents, and other third-parties registering, promoting, selling, or supplying Integra products or otherwise interacting with government officials (includes any State or National government department, ministry, agency, instrumentality, military organization, government-owned or controlled company, political party or a former/current elected official, public international organization, or any employee or official of the above.) or healthcare providers on Integra’s behalf.