Wright Code of Business Conduct
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Code of Business Conduct

First Choice in Extremities and Biologics

Dear Wright Colleagues, In 2011, I joined a Company with a tremendous amount of potential. As I reflect back on what has changed and what we’ve accomplished, I am confident that we are on a path that will motivate our employees, delight our customers and satisfy our shareholders. We have innovative and high quality products, an exciting pipeline, and a focused global growth strategy in extremities and biologics. More importantly, we have passionate people committed to making a difference. Every publicly traded company has a Code of Business Conduct (“Code”) in some form. Most companies of...

Questions or concerns? Email ethics@wright.com or call 901.867.4

“I am confident that we are on a path that will motivate our employees, delight our customers, and satisfy our shareholders.” Robert Palmisano, President & CEO

Introduction Directive Mission We focus on Extremities and Biologics. Through our team of passionate and dedicated people, we deliver innovative, value-added solutions improving quality of life for patients worldwide. We are committed to compliance and the highest standards of ethical conduct. This Code of Business Conduct (“Code”) applies to all personnel of Wright Medical Group N.V. and its subsidiaries. We are committed to compliance and the highest standards of ethical conduct. The most fundamental principle of the Code is that all business conducted by the people who represent the...

“It is not only what we do, but also what we do not do, for which we are accountable.” Moliere

“To keep a customer demands as much skill as to win one.” American Prover

PERSONAL ACCOUNTABILITY Company Representative Responsibility – Does the Code Apply to Me? The Code applies to all employees (full-time, part-time and temporary), officers, and members of the Board of Directors of Wright, as well as agents, distributors, contractors and other third parties when acting on behalf of the Company; the Code refers to any person in one of these categories as a “Company Representative.” Nothing in the Code shall be construed to influence the independent professional judgment of a Health Care Professional in regard to patient care and treatment. Where can I find...

Q& A What do I do if my team member brings a policy violation to my attention? Once you are made aware of a potential problem, you must escalate that concern to the Compliance department immediately. You must also instruct your team member to make a report using one of the avenues provided. Ethics Quick Test If you know that it’s wrong or suspect that it might be wrong, don’t do it! If you are not sure, ask. Wright is committed to provide guidance to Company Representatives in making the right decisions. The following “ethics quick test” helps to make an assessment when there are doubts...

“Adaptability is about the powerful difference between adapting to cope and adapting to win.” Max McKeow

INTEGRITY IN THE MARKETPLACE Every Company Representative is expected to perform with integrity in the marketplace. This can be achieved by following applicable laws and regulations as well as the company policies set forth by Wright. As a Company Representative, you are expected to complete training and understand the relevant laws, policies, and compliance processes. Each Company Representative is obligated to comply with the Code, and failing to do so can result in fines, penalties, and/or damage to the Company’s reputation. Relationships with Health Care Professionals Wright’s...

Can I create product marketing materials tailored for my customer? Company Representatives are prohibited from independently developing or distributing marketing materials. All presentations, marketing materials, etc. involving the branding, labeling, or use of Wright products must be approved through the Legal and Regulatory departments to ensure compliance with product indications as approved by the FDA. Quality Policy Our commitment to Quality, product safety, and regulatory compliance makes us your first choice in extremities and biologics. We achieve this through continuous quality...

Anti-Bribery and Anti-Corruption Laws (“ABAC”) Globally, there are Anti-Bribery and AntiCorruption laws in place to foster ethical behavior between government and business. The cornerstone of these laws prohibits any person (or corporation) from knowingly or willfully offering, paying, soliciting or receiving cash or anything of value with a purpose to create an unfair advantage. Anti-Bribery and AntiCorruption Laws include but are not limited to: • The US Foreign Corrupt Practices Act (“FCPA”) anti-bribery provisions apply to corrupt payments made to 1) any foreign official; 2) any foreign...

Questions or concerns? Email ethics@wright.com or call 901.867.4349

Use and Protection of Confidential Patient and Prescriber Information Who is considered a foreign official according to the FCPA? Company Representatives are obligated to comply with laws and rules relating to protecting confidential patient health information. This protected information includes all individually identifiable information relating to: A foreign official is defined broadly and includes: • an individual’s past, present, or future physical or mental health or condition; • the provision of health care to an individual; or • payment for providing health care to an individual....

“Coming together is a beginning. Keeping together is progress. Working together is success.” Henry For

ETHICS IN BUSINESS Global Conduct Standards under the Code Wright’s business activities are conducted in a complex world of laws and regulations. As a company with global presence, such laws and regulations vary from one geographic region to another, and it is the responsibility of our Company Representatives to ensure that their business activities comply with all laws and regulations relative to their respective locations. In addition to local laws and regulations, Company Representatives must also ensure that they are engaging in business activities that are in compliance with the...