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Anti-Corruption Guideline

Our emphasis on responsible action calls for transparent and lawful collaboration with sales partners, physicians, medical facilities, and other medical staff (1) following a clear code of conduct (2). We strictly reject and will not tolerate corrupt or otherwise unlawful behavior. All KARL STORZ managers and staff are therefore asked to observe legal requirements as well as the below code of conduct and to implement them in their everyday work. Doing so will increase the trust placed in KARL STORZ in the competitive environment.

In general:

KARL STORZ managers and staff must not offer, promise, or grant personal advantages with the intention of directly or indirectly influencing procurement decisions to sales partners, physicians, medical facilities, or other medical staff. Likewise, KARL STORZ managers and staff must not demand or accept personal advantages if they may be intended to exert undue influence.

Specifically:

  • Unjustified payments without legal bases that are made with corrupt intentions (eg, fictitious expense reports, concealed cash payments, fake invoices) must not be made or accepted.
  • Giving or accepting gifts and other personal advantages is permissible only if their total value and the specific circumstances of the particular case do not create the impression that the respective recipient of the advantage is expected to behave in a certain way in return. Therefore, the only permissible gifts are inexpensive promotional gifts and, in exceptional cases, personal gifts at special occasions, provided that they are socially appropriate and related to the professional environment.
  • Donations must be pledged only to recognized non-profit organizations and only with explicit authorization by KARL STORZ management; they must further comply with the company's internal framework conditions.
  • Privately entertaining sales partners, physicians, medical facilities, and other medical staff is not permissible in the absence of a business occasion. Appropriate and socially adequate entertaining is only permissible in the context of official events or business meals.
  • Inviting sales partners, physicians, or other staff of medical facilities to participate in conferences, informational events, or educational events is permissible. However, KARL STORZ will reimburse the resulting costs only if they are appropriate and directly related to the event.
  • Research projects and research studies conducted by medical facilities as well as post-marketing surveillance studies on behalf of KARL STORZ are permissible if the medical facility has a reasonable interest in collaboration and if the projects are scientifically/medically justified. Each individual case must be approved by KARL STORZ management. Generally, the medical facility or its carrier is the contractual partner and recipient of reasonable compensation. In exceptional cases where an employee of the medical facility is the contractual partner, KARL STORZ must be presented with a written authorization for the employee to hold an outside job issued by the employer.
  • Agreements on clinical trials and performance evaluations are to be entered into with the medical facility or its carrier in consultation with the investigator. The compensation must be transferred exclusively to a bank account of the medical facility. Entering into agreements with the investigator personally is only permissible in exceptional cases and with the employer's written permission for the employee to hold an outside job.
  • Sponsoring for the purposes of promoting the KARL STORZ image and its products is limited to the medical facility/company and is not to benefit specific persons within those facilities. The recipient of payments shall always be the medical facility/company.
  • For activities outside of Germany, the potentially more strict anti-corruption legislation of other countries is observed.
  • Each individual is responsible for the lawfulness of his or her actions. Furthermore, the KARL STORZ management will thoroughly verify compliance with this code of conduct. In the event of violations of this code of conduct, KARL STORZ reserves the right to take further legal measures.

Note: Please note that special rules apply to activities related to the United States of America.

(1) This information also applies to all business partners outside of the field of medicine and is not limited to the listed sales partners, medical facilities, and physicians.

(2) The below code of conduct is based on our detailed, internal anti-corruption guideline, which we will gladly supply upon request.

In case of questions, please contact the KARL STORZ anti-corruption officer.