In performing their duties for Globus, each employee maintains the highest standards of honest and ethical conduct in all dealings with other employees, customers, suppliers, and other third parties of the Company, including the independent auditors of Globus and any government or regulatory agencies.

All employees avoids any actual or perceived conflict of interest between personal and professional relationships. When there is any question about the possibility of a potential conflict of interest, the employee will report the transaction or action immediately to the Board of Directors of the Company. Employees will take all reasonable measures to protect the confidentiality of non-public information about the Company.

Any interpretation of the provisions of this Code, as well as Globus’ and its employees and agents interactions with healthcare professionals not specifically addressed in this Code, should be made in light of the following principle: Globus encourages ethical business practices and socially responsible conduct and its employees and agents shall not use any unlawful inducement in order to sell, lease, recommend, or arrange for the sale, lease or recommendation of Globus products. Additionally, Globus has adopted the AdvaMed Code of Ethics as Company policy.

The Company’s accounting records and reports will be maintained in a fair and accurate manner in accordance with all applicable laws and consistent with all generally accepted accounting standards. In addition, all employees comply with and take all reasonable action to ensure others comply with all applicable governmental laws, rules and regulations.

Globus Medical Code of Ethics AdvaMed Code of Ethics