Globus Medical Anti-Slavery Policy
CORPORATEPOLICIES

Globus Medical, Inc. (“Globus”) is committed to establishing and maintaining the highest
standards of ethical practice in all areas of its business. In accordance with this commitment,
Globus has developed policies, procedures, and training designed to ensure that our business is run
ethically and in compliance with relevant laws and regulations.
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Purpose and Scope

This policy addresses measures Globus takes to ensure that modern slavery is not occurring in ourbusiness and within our supply chains.
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Responsibility

While all Globus employees are responsible for compliance with this policy, Globus’s legal
department has overall responsibility for implementing this policy, monitoring its effectiveness,
responding to any queries, and ensuring this policy complies with our legal and ethical obligations.
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Definition of Modern Slavery

Modern slavery is defined as the recruitment, movement, harboring or receiving of individuals
through the use of force, coercion, abuse of vulnerability, deception, or other means for the purposeof exploitation. It takes various forms, including slavery, servitude, forced or compulsory labor,
and human trafficking. Modern slavery is a crime and a violation of fundamental human rights,
and is not tolerated in any form by Globus. If a Globus employee has any questions over whether
a particular circumstance constitutes modern slavery, that employee must raise that question withthe legal department or submit it through the Compliance Hotline for evaluation.
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PolicyGlobus expects each and every employee to cooperate and comply with the company’s zerotolerance approach to modern slavery, remain vigilant in identifying circumstances where modern
slavery might be occurring, report any such circumstances to senior management in full andwithout delay (or alternatively report any such circumstances to the Compliance Hotline atwww.globusmedical.ethicspoint.com), and avoid any activity that might violate or suggest a
violation of this policy. Any reports regarding actual or possible violations of this policy will beinvestigated immediately and thoroughly.
Globus further expects all of its third party supply chain and any individual or company working
for us or on our behalf in any capacity to follow this policy. In our standard supplier contracts,
Globus suppliers represent that they conduct business in compliance with all applicable laws andregulations, which would include any laws addressing slavery and human trafficking. In thosecontracts, our suppliers also covenant and agree to notify Globus immediately upon the occurrenceof an event that would render such representation incorrect or misleading. Globus willcommunicate this policy to its suppliers at the outset of the business relationship and may engage
in verification measures as appropriate to evaluate and address any risk of modern slavery in oursupply chain.
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Compliance

Any party to whom this policy applies will be expected to cooperate fully with any investigation
into suspected breaches of this policy or any matters related to this policy. Any employee violating
this policy will be subject to disciplinary action up to and including termination. Globus may
terminate its business relationship with any third party who breaches this policy.
Retaliation of any kind or discrimination against an employee who makes a report consistent withthis policy is prohibited. Any such retaliation or discrimination will be subject to discipline up toand including termination.
This policy does not form part of any employment contract between Globus and any other party.
Globus may amend this policy at any time.

Last revised: November 25, 2020