Declaration Pursuant to California Health and Safety Code §119402(e) – June 2018
As part of our continued efforts in the area of compliance, Glaukos has developed a Comprehensive Compliance Program (“CCP”) that is reasonably designed to prevent and detect violations. Consistent with industry practice and various government guidance documents, we have tailored our CCP to the nature of our business as a medical device manufacturer. The medical device industry has established, and Glaukos’ CCP is designed in accordance with, a voluntary ethical code called the AdvaMed Code of Ethics on Interactions with Health Care Professionals (AdvaMed Code). The AdvaMed Code is substantially equivalent to the Pharmaceutical Research and Manufacturers of America Code on Interactions with Health Care Professionals (PhRMA Code), but reflects the unique interactions between medical technology companies and health care professionals.
Government standards on compliance recognize that even an effective CCP may not completely eliminate improper conduct by individual employees. Recognizing that compliance is a dynamic concept, Glaukos continually reviews and updates its CCP to improve it. As a result, the Program periodically incorporates changes in policy and approach that require the subsequent development of new and upgraded systems and processes.
To the best of our knowledge, and based on our good faith understanding of the statutory requirements, we have established a CCP that is compliant with the requirements of California Health and Safety Code §§119400 – 119402, and we are in compliance with our CCP with respect to our business and operations in the State of California in all material respects.
As noted in the Compliance and Ethics Program description, it is possible, and likely, that we will update our Program on an ongoing basis. Copies of this Declaration and the Compliance and Ethics Program description may be obtained by calling 1-866-GLAUKOS, ext 1429.