Structure of Haemonetics Compliance Program
Haemonetics maintains a global compliance program designed to help ensure compliance by our employees and third-party partners with various Haemonetics policies and applicable laws relating to, among other topics, anti-bribery and anti-corruption and marketing and sales practices involving health care professionals.
Oversight & Management
Our Chief Compliance Officer (CCO) leads our Global Compliance function and has a direct reporting line to Haemonetics General Counsel as well as the Governance and Compliance Committee of our Board of Directors. The CCO along with compliance program personnel have day-to-day responsibility for overseeing the implementation and effectiveness of Haemonetics Compliance Program.
Written Policies & Procedures
Our Code of Conduct is the cornerstone of our compliance program and describes our commitment to operate in accordance with accepted standards, company policies and applicable laws and regulations. It is the expectation that all Haemonetics employees will comply with our Code and the policies and procedures that have been established in support of the Code.
Training & Education
We provide ongoing training and education to all employees and relevant stakeholders regarding compliance with applicable laws, regulations, our Code of Conduct and internal policies. Compliance program training and education programs include practical guidance to support our employees in making ethical business decisions.
Monitoring & Auditing
Our program includes ongoing efforts to proactively monitor, audit and assess compliance with our Code of Conduct and Compliance Program policies and procedures. Compliance Program personnel work with our internal audit function to monitor compliance as well as support preventative and corrective actions.
Reporting Mechanisms
Haemonetics is committed to fostering effective lines of communication between management and employees. We provide mechanisms for employees and stakeholders to report concerns or suspected violations of compliance policies without the fear of retaliation, including maintaining an anonymous reporting line, the Haemonetics Integrity Helpline.
Responsiveness & Corrective Action
Our Compliance Program includes processes for responding promptly and impartially to reports of non-compliance as well as conducting investigations of such reports. Although each situation is considered on a case-by-case basis, Haemonetics will take appropriate corrective and disciplinary action to address non-compliance, misconduct and deter future violations.
Global Transparency
Haemonetics believes that transparency fosters trust, accountability, and ethical relationships with healthcare professionals and organizations. We are committed to complying with global transparency laws applicable to our company, including the reporting requirements under the U.S. Sunshine Act, the European MedTech Code, and other international transparency initiatives.
Links to certain of our global transparency documents are included below:
Japan
Transparency Guidelines 2019
Transparency Guidelines 2020
Transparency Guidelines 2021
Italy
Modello di organizzazione, gestione e controllo ai sensi del D. Lgs. 231/01 - Parte Speciale
Modello di organizzazione, gestione e controllo ai sensi del D. Lgs. 231/01 - Parte Generale
Trasparenza - Confindustria Dispositivi Medici
Haemonetics Italia – Whistleblowing Procedure – Bilingual
U.S. – California
California Comprehensive Compliance Program
Links to certain of our global transparency documents are included below:
Japan
Transparency Guidelines 2019
Transparency Guidelines 2020
Transparency Guidelines 2021
Italy
Modello di organizzazione, gestione e controllo ai sensi del D. Lgs. 231/01 - Parte Speciale
Modello di organizzazione, gestione e controllo ai sensi del D. Lgs. 231/01 - Parte Generale
Trasparenza - Confindustria Dispositivi Medici
Haemonetics Italia – Whistleblowing Procedure – Bilingual
U.S. – California
California Comprehensive Compliance Program