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Compliance Program

Facet Technologies, LLC Compliance Program

Facet Technologies, LLC (“Facet Technologies”) has a comprehensive compliance program for its United States operations that is consistent with voluntary guidelines published by the Office of Inspector General (OIG) of the United States Department of Health and Human Services. As a medical device manufacturer, Facet Technologies’ United States compliance policies and procedures address the provisions published by the Advanced Medical Technology Association (“AdvaMed”) of the voluntary AdvaMed Code of Ethics on Interactions with Health Care Professionals (the “AdvaMed Code”). The AdvaMed Code was developed to provide guidance specifically to the medical device industry. The AdvaMed Code is the equivalent to the voluntary Pharmaceutical Research and Manufacturers of America (“PhRMA”) Code on Interactions with Healthcare Professionals (the “PhRMA Code”), which was designed to provide guidance to the pharmaceutical ]industry.

As of the date of this declaration, Facet Technologies believes that its United States operations are in material compliance with its comprehensive compliance program and the provisions of § 119402 of the California Health and Safety Code.

This declaration is made solely for the purpose of complying with the California law cited above and should not be read in isolation from Facet Technologies’ other discussions of its compliance related activities and information disclosed currently or in the future on this website or in its periodic reports, press releases and elsewhere.

Last updated: April __, 2017