Mindray North America is headquartered in Mahwah, NJ.
COMPREHENSIVE COMPLIANCE PROGRAM DESCRIPTION
- INTRODUCTION
Mindray North America follows its Mindray Compliance Program (MCP) and is committed to conducting its business in accordance with the highest ethical and compliance standards. A key component of this commitment is our establishment and maintenance of the MCP in accordance with the HHS-OIG Guidance. We expect our employees to comply with our MCP, and we investigate and appropriately resolve potential violations of the MCP, applicable laws, regulations, industry codes and other Company policies. Where appropriate, we take disciplinary action, up to and including termination, and implement corrective measures to prevent future violations.
- COMPLIANCE PROGRAM OVERVIEW
A. Leadership and Structure
Privacy Officer. The Information Security & Compliance Principal, is charged with developing, operating and monitoring the MCP. This individual reports directly to our Senior Corporate Attorney.
Security & Compliance Committee. Mindray North America has established a Security & Compliance Committee to advise management and to assist in the implementation of the MCP at the Company. The Compliance Committee is comprised of senior members of functional units across the Company, including marketing, IT, research and development, legal, regulatory, and human resources. The Committee meets on a regular basis to monitor Company activities and compliance developments.
B. Written standards
Mindray North America has established its commitment to compliance through a number of Company communications and trainings. Mindray North America has also established a total annual dollar limit on items of value (including meals) that the Company may provide to California HCPs in accordance with Advamed (https://www.advamed.org/member-center/resource-library/advamed-code-of-ethics/). The Company’s established limit for educational items is $100 of market value per occurrence. This limit may be revised by the Company from time to time. Per Cal. Health & Safety Code §§ 119400-119402.
C. Education and Training
We regularly provide compliance training to all Mindray North America employees, including at new hire orientation. We train employees in our MCP, Company policies, and on all applicable laws, regulations and industry codes.
D. Internal Lines of Communication
We employ a variety of internal communication tools to communicate with employees about compliance issues and concerns. These include an intranet website for the Ethics & Compliance Department and regularly distributed newsletter.In addition, we routinely respond to compliance questions from individual employees and regularly respond to compliance inquiries and address compliance issues at company meetings and through regular compliance communications. We instruct employees on their obligation to report actual or potential compliance violations, and we provide them with various resources including an independent, third-party operated Compliance Hotline by which they can anonymously, if they wish to do so, report compliance questions, concerns, or violations.
E. Auditing and Monitoring
Mindray North America performs annual compliance risk assessments, routine compliance monitoring and compliance audits. Reports of these activities are made to senior management. Identified issues and opportunities for enhancement are addressed, and education, training and corrective action are taken when necessary.
F. Responding to Potential Violations
Our MCP requires that the Company respond promptly to potential violations of law, regulation, industry codes or Company policies. Potential violations are investigated and evaluated on a case-by-case basis. Disciplinary action, up to and including termination, is taken when deemed appropriate.
G. Corrective Action Procedures
After investigation of a reported or detected compliance issue, the Company assesses whether additional corrective action is appropriate. The assessment includes a determination as to whether a violation is due, in part, to any gaps in our policies, training or internal controls. If a gap is identified, the Company will take action to correct it.
To request a copy of the Mindray North America Declaration and Comprehensive Compliance Program description, please call 844-979-4916.