How do I report a potential compliance issue?
Reporting and Resolution Process
Reporting a Potential Violation
Each Team Member (including Biomet distributors and sales representatives) is responsible for conducting himself or herself according to legal and ethical standards. In addition, everyone has a responsibility to report in a timely fashion any violations of the Biomet Code of Business Conduct. Team Members will not be subject to reprisals for reporting or supplying information about potential violations and the Company expects Team Members to fully cooperate in any investigation of a potential violation. Biomet is committed to non-retaliation and to maintaining confidentiality and anonymity with respect to such reports.
If a Team Member needs guidance on a legal or ethical question or has witnessed/has knowledge of an illegal or unethical activity, he or she should seek the counsel of his or her supervisor. If approaching the supervisor is uncomfortable, or if the response is unsatisfactory, Team Members should consult senior management, Biomet legal counsel, Biomet's Compliance Department and/or the Human Resources Department. Phone numbers for these offices can be found in the company telephone listing.
If Team Members prefer, compliance questions or reports about potential violations may be directed to Biomet toll free helpline, 1-800-348-9500, ext. 1759. Team Members may choose to remain anonymous when reporting a potential violation on the helpline. Team Members may submit reports through the following website: https://secure.ethicspoint.com/domain/media/en/gui/20120/index.html. As with all questions or inquiries, the information given will be treated as confidential to the extent possible.
Investigations and Corrective Action
All reports of alleged violations will be investigated by the Company and will be treated confidentially to the extent applicable law permits. If the results of an investigation indicate that corrective action is required, the Company will decide the appropriate steps to take, including Team Member discipline, dismissal and possible legal proceedings. If appropriate, the investigation may be turned over to applicable outside authorities, and outside investigators may assist in the inquiry. As part of the closure process, results of an investigation may be shared with the initiator of the report.
In the past, members of the health care industry (doctors, hospitals, companies and others) have been the subject of various government investigations. It is Biomet's policy to fully cooperate with valid government investigations. While not likely, it is possible that Biomet Team Members may be contacted by government officials conducting an investigation of the medical device industry. Team Members should be aware that such investigations may be complex, and if contacted by an investigator, are encouraged to verify that Biomet is aware of the investigation.
Response and Discipline for Ethics Violations
Each Team Member is responsible and accountable for adhering to this Code of Business Conduct. Team Members who violate provisions outlined in the Code could be subject to appropriate disciplinary action, including termination.