BlueWind Medical requires behavior that is compliant, ethical and lawful at all times. Our Code of Ethics and Conduct on Business Interactions with Healthcare Professionals (“the Standards”) is intended to provide a roadmap for our day-to-day behavior. It is a fundamental document and statement on the way we do business. Operating with the highest degree of integrity is not an option for any employee; it is a requirement for each and everyone of us who work here. Know that even when the stakes are high and the circumstances are difficult, I expect each and every employee to do the right thing. We are all responsible and accountable for our patients’ trust–and our company’s reputation.

While the Standards cannot provide definitive answers to all questions or situations, it is intended to provide general guidance regarding common issues that are vital to one another, our physician partners, and to our patients. We must ultimately rely on our own ethical compass-including a sense of when it is appropriate to seek guidance on the appropriate course of conduct. Finding an answer or solution in any given situation is not always easy or straightforward; however, a few things are always clear. We will be honest with ourselves and each other and foster an environment that encourages treating everyone with honesty and respect. And at the end of the day, we do the right thing.

If you witness behavior that violates the Standards or any of our company policies, I expect you to speak up through the communication channels available to you:tell your manager, VP of Compliance, VP ofHuman Resources, or call me. You also have the option to utilize the BlueWind Medical Helpline which allows you to submit an anonymous question or report an issue. I assure you that any suspected instance of non-compliance will be addressed promptly, and I also assure you that BlueWind Medical prohibits retaliation against anyone who voices a concern in good faith. I am personally committed to promoting an environment that is safe, compliant, and encourages people to raise issues.

Dan Lemaitre
Chairman & CEO