Code of Conduct

Introduction

As an owner-managed medical technology company, we are committed to legally compliant and socially responsible corporate management. Every company in the LINK Group complies with the applicable laws and other regulations of the countries in which it operates. Observance of the laws of the respective country is the minimum requirement for our activities. Accordingly, the company respects applicable law and expects the same from all its employees. Unlawful conduct can cause major commercial damage. Even the impression that laws are infringed can be detrimental the company’s market position. The consequences of our own actions must therefore be measured against how they impact on the company’s reputation and its integrity. Every action must be underpinned by a clear understanding of the applicable laws and regulations, corporate guidelines and shared values. This Code of Conduct describes the framework within which the company’s objectives are implemented on a daily basis. The purpose of the Code of Conduct is to facilitate compliance with legal regulations and internal rules, but it cannot provide an exhaustive list of all the duties pertaining to all the legal systems within which the company operates. Our employees are therefore under an obligation to obtain expert advice in case of doubt. Employees should consult their line managers or the specialist departments whenever questions arise. The Code of Conduct is further defined and supplemented by additional guidelines as required.

1. General rules of conduct

The principle of tolerance, respect, objectivity and fairness applies in our dealings with one another and with third parties, as set out in our corporate philosophy (https://www.linkorthopaedics.com/de/ueber-link/unternehmen/leitbild/). This also applies to our use of Social Media. Employees must at all times keep their private interests separate from those of the company.

2. Conduct in business matters

The company competes in the market on the basis of fairness and legal compliance.

Bribery and corruption
Bribery and corruption will not be tolerated by the company. The company’s reputation, acceptance and business activity as a trustworthy market player must not be put at risk by these offenses.

Dealings with decision-makers in the public health sector
Employees must not offer, grant or authorize inappropriate benefits to public health decision-makers. This includes money, goods, services, and other unjustified benefits. At the interfaces between medically indicated use of our products and business practice, the relationship must always be such that it does not create the impression that cooperation with medical professionals and institutions might compromise the neutrality and independence of either party. In particular, no actions are permitted which cause an infringement of criminal law, the law governing advertising of medicines or the unfair competition law. To ensure that this requirement is met, every service rendered to public health decision-makers must comply with the following four principles: Separation principle (benefits granted must not be connected with procurement decisions), transparency principle (any benefit or remuneration must be disclosed in compliance with the applicable laws), documentation principle (all services rendered must be recorded in writing) and equivalence principle (service rendered and return service must be commensurate).

Competition
LINK is committed to fair competition and, in particular, does not participate in formal or informal agreements with other companies which serve the purpose or have the effect of producing a prohibited restriction, limitation or distortion of competition.

Money laundering
Enabling the proceeds of criminal activity to be transferred into legal financial and commercial circulation while concealing its true origin and other money laundering activities in Germany and other countries are prohibited.

Export
All national and international customs, export and foreign trade regulations must be observed.

Financial reporting and obligatory documentation
Business transactions must be documented appropriately and faithfully. Complete and correct recording of information that is relevant for accounting and tax purposes must be assured. Legal and official retention periods for documents must be observed.

3. Product safety and quality

We fulfill our product monitoring obligations fully and thoroughly, and we train and inform the users of our products on an ongoing basis. Every LINK product conforms to at least the current state of the art, all legal requirements and regulations, and also our in-house safety and quality rules. Every member of staff is responsible for making sure that these quality requirements are implemented effectively and that all complaints are recorded and rectified in a timely manner.

4. Protection of corporate assets

The company’s assets must be preserved and protected.

Conflicts of interest
All employees must avoid, wherever possible, any conflict in their work activity between their personal financial interest and the company’s commercial interest. Any such conflict must otherwise be reported to their line manager, as must any benefit which the employee is offered by a third party in relation to his work activity (e.g., invitations and/or gifts from suppliers and service providers). Such benefits may only be accepted if approved by the line manager.

Business secrets 
Business secrets must be treated confidentially, and relevant digital and analog data media must be labeled confidential and kept in a safe place where they cannot be accessed by unauthorized persons.

5. Fairness and protection for employees and applicants

In all decisions relating to employees and job applicants, unequal treatment for reasons of nationality, ethnicity, skin color, age or appearance, sex, disability, sexual identity, religion or conviction and any other characteristics protected by law is to be avoided.

We provide our employees with secure jobs. All of our employees observe all occupational health and safety regulations. Line managers are responsible for ensuring that employees are adequately trained in work safety measures.

6. Cooperation with authorities

Regulatory obligations in relation to the responsible authorities must be met. The company places importance on a good, cooperative relationship with all the responsible authorities. Therefore, information must always be submitted fully, correctly and promptly.

7. Relationship with the media and government agencies

Inquiries from the media and government agencies must only be answered by employees who are specifically and expressly authorized to do so.

8. Data protection and use of electronic media

The company undertakes to treat personal data confidentially and to only collect, process and store such data in compliance with applicable data protection regulations. If the company provides access to and use of electronic media for business purposes, such media must not be used for purposes that conflict with laws, regulations, directives or guidelines and other company rules.

9. Environmental and health protection

The company is committed to protecting the environment and human health.

10. Final instruction

Infringements of this code of practice will not be accepted and may lead to disciplinary measures or even dismissal and, depending on the nature of the infringement, may result in civil liability actions and prosecution. Every LINK employee must report all possible breaches of the Code of Conduct or other violations of law to his/her line manager or - if he/she fears a conflict of interest - the line manager’s superior. The company gives its assurance that no employee who reports irregularities or suspicions will be in any way disadvantaged as a result.