TELEFLEX INTEGRITY CODE
Teleflex is committed to ensuring that Teleflex employees and agents (“Associates”) adhere to the highest
standards of conduct, including compliance with all applicable anti-kickback, anti-bribery, ethical business andanti-corruption laws in each country where Teleflex conducts business. In addition, Teleflex understands andrespects the obligations of Government Officials (“GOs”) to their respective governments and Health Care
Professionals (which includes Health Care Organizations (“HCPs”)) worldwide to act in the best interest of – andmake independent decisions regarding – the health care of their patients. This set of Policies is intended toensure Teleflex Associates continue to conduct business worldwide in accordance with our core values. ThesePolicies are intended to provide additional direction and clarity to Teleflex’s existing policies regarding anticorruption and interactions with HCPs and GOs.
It is the responsibility of each Business Unit and Regional President (“BRP”) to implement appropriate internal
processes to ensure compliance with this Code, including processes that document adherence to each Policy
set out below for auditing and monitoring purposes. This includes the provision of training on the Code and each
Policy in coordination with the Chief Compliance Officer (“CCO”). In all instances where BRP or CCO is used inthis Code, the term also includes the BRP’s or CCO’s designee.
This Code provides guidance on the following subject matter areas:

1. Gifts, Entertainment, and Appropriate Business Meals
2. Educational and Research Grants
3. HCP Engagements
4. Congresses, Trade Shows, and Academies
5. Samples and Product Evaluations
6. Market Research
7. Authorship
8. Patient Interactions
9. Teleflex Medical Training and Education
10. Humanitarian Aid and Charitable Donations
11. Reporting Compliance Concerns
This Code DOES NOT cover the following topics: 1) Clinical Research led by Teleflex; 2) Adverse EventReporting; 3) Global Trade Compliance; 4) Anti-Trust; 5) Off-label Promotion, Mislabeling, Misbranding; or 6) thePromotional Review Process. Guidance around these topics is covered in other legal, regulatory, and CMA
policies and procedures. This Code is intended to cover the most common interactions with HCPs and GOs byTeleflex Associates.
•Policy #1 – Gifts, Entertainment, and Appropriate Business MealsoGifts. Teleflex Associates may not provide gifts or educational items to GOs, HCPs orpatients (including personal gifts) outside of the circumstances set out in the applicable
Gifts IPP without the written permission of the BRP and CCO. In particular, gifts of cash orcash equivalents (e.g. gift certificates and gift cards) must never be given to a GO orHCP.

oAny gift permitted by the BRP and CCO must be modest, reasonable, and in compliancewith all applicable IPPs, and given infrequently, so far as any individual recipient isconcerned. All permitted gifts must be of a nature that would not negatively impact

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Teleflex’s reputation if the gift were to be publically disclosed and should be aligned with
cultural courtesy in the applicable region.

•oNo gifts or educational items can be provided to improperly influence or reward an act ordecision for any benefit to Teleflex nor in response to a request made by an HCP or GO.

oEntertainment. Teleflex Associates may never provide entertainment to GOs or HCPs.
This includes but is not limited to: 1) no golf/tennis outings; 2) no concerts; 3) no sportingevents; 4) no tourist attraction events or sightseeing; 5) no theater tickets; or 6) no engaging
in or facilitating any activity that may be perceived as entertainment.

oAppropriate Business Meals. It is permissible and appropriate to have a drink, meal, orappetizers at a local hotel, restaurant, or bar with a proper business purpose with a GO orHCP, as long as, the venue itself cannot be considered entertainment (e.g. House of Blues,Hooters, etc.) and such interaction is permitted under local law.

oMeals can be provided during a sales, promotional, or other business discussion with theHCPs or GOs; however, Teleflex may not fund the costs of individual HCP’s or GO’s travel
and accommodation for the purposes of sales and promotional meetings. Sales,promotional, and other business meetings are meetings between one or more HCPs andone or more Teleflex Personnel to discuss Medical Technology features, sales terms orcontracts.

oTeleflex will neither provide nor pay for alcoholic beverages except during the dinner hour,and in general no more than two to three drinks per attendee. The entire bill, inclusive of
all food and beverages, must be within meal limitations set forth in the Business Meals IPP.

oRegional finance should: 1) reimburse meal expenses in accordance with local laws; 2)establish monetary limits for GO and HCP business meals in local currency; and 3) monitor
local compliance with such limits. Frequent or repeated violations of the GO or HCP
business meal limits should be elevated to the BRP and CCO.

Policy #2 – Educational and Research Grants
oIndependence. Educational and Research Grants will not be provided or offered as areward for past business or an inducement for future business to any HCP or to curry favorwith any GO. Educational and Research Grants must be controlled by the recipient andTeleflex should not be involved in any way that is intended to inappropriately influence thecontent or activity funded by the Grant. Grants shall only be provided in response to awritten request from Health Care Organizations or Conference Organizers. Educationaland Research Grants may not be given to individuals.

oRequests. Teleflex Associates (e.g. Sales and Marketing) may not solicit, suggest, orrecommend that any HCP or GO seek a Grant from Teleflex or submit a Grant request on
behalf of an HCP or GO. This includes Grant requests related to sending HCPs to industry
trade shows or congresses for educational purposes. All requests should come directlyfrom the Health Care Organization or Conference Organizer to Clinical and Medical Affairs
in the applicable region for review without input from sales personnel directly responsible
for the customer account submitting the request.

oReview and Approval/Denial. Each region must set up a Grant Panel to review allEducation Grants submitted by HCPs or GOs to Teleflex. Each Grant Panel will include atminimum four (4) members with at least one (1) representative from the following
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departments: CMA, commercial, compliance, and finance. A member of CMA will beappointed as the Chairman of each Grant Panel. Each grant will be reviewed by the Grant
Panel to ensure the following:
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It complies with all applicable continuing education credit requirements in theapplicable region;Due diligence is conducted regarding the reputation of the institution, organization,or association to verify the legitimacy of the organization making the request;
The request relates to Teleflex’s therapeutic areas and interest in ensuring thatHCPs or GOs are properly educated on the standard of care related to our products
to enhance patient safety and the delivery of healthcare worldwide; andFor Educational Grants related to a congress, cost of travel, venue and the event
program will be evaluated.

oLetter of Agreement. All approved Grants must be documented in a Letter of Agreement
between Teleflex and the organization receiving the Grant. All Education Grants must befor the advancement of genuine medical education and Teleflex shall specify the intended
purpose of the Grant in the Agreement.

oPayments/In-kind Support. The amount of the Grant must be justified and reasonable,
bearing in mind the subject matter of the request and all of the facts of the particularsituation. Teleflex’s support must not be excessive, so as to jeopardize the independenceof the recipient’s program. Finance must not release payment for any Grant without written
documentation of Grant Panel approval and a signed Letter of Agreement including theexact amount approved. CMA is responsible to ensure that the funds are used as intended
and any unused funds are returned back to Teleflex.

oDocumentation. The Chairman of each region’s Grant Panel is responsible for allcommunication with Grant requestors regarding approval/denial and the status of all Grant
requests. This responsibility cannot be delegated to sales personnel. The Grant Panel willkeep documentation for (5) years of all Grant requests, their approval/denial status, theamount (if any) approved, and confirmation of payment /in-kind support to any recipient.
For all Grant payments related to congress or trade show attendees, proof of attendancemust also be verified and documented.

Policy #3 – HCP and GO Engagements
oLegitimate Need. There must be a legitimate business purpose that is identified in theAnnual Needs Assessment for the services provided by any HCP or GO Consultant. This
service must be documented in a written agreement. It is never a legitimate businesspurpose to engage an HCP or GO 1) to improve a relationship with an HCP or GO; 2) togain access to an HCP or GO; or 3) to reward an HCP or GO for past or future business.

oSelecting an HCP or GO. CMA should establish a process around selecting HCPs andGOs to perform consulting services for Teleflex within the following Policy:

The HCP’s/GO’s qualifications support the identified business needs of theengagement;
The number of HCPs/GOs contracted is appropriate to the needs identified (e.g.
engaging six (6) for a Scientific Advisory Board instead of nine (9), if six (6) is allthat is reasonably needed);
The frequency of the number of engagements for any one HCP or GO isreasonable and justified;3
oThe HCP or GO is screened for any criteria that might render the HCP or GOineligible to perform work for Teleflex (e.g. sanctions, exclusions, conflicts ofinterest, felony convictions, medical license in good standing, or debarment); andCommercial reasonableness is documented and approved by CMA for any HCPs
traveling outside of their region to perform consulting services.
Where applicable, local legal and industry code requirements to notify an HCP’sor GO’s employer and/or obtaining permission from the applicable local regulatory
body are met.

Payments to HCPs or GOs.
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Finance must implement local processes governing HCP/GO payments in eachregion. The documented process must include verification of the following prior topayment: 1) an executed written agreement between the parties; 2) performanceof the services; 3) validity of all expenses; 4) all payments are directed to an
account or address in the HCP’s primary country of medical practice (or for GO’s
the country where they perform services for the local government) and not directed
to charities or similar organizations; and 5) all payments are consistent with fairmarket value (“FMV”) in the region and paid according to the financial terms of thewritten agreement.
If required, a process must be established to meet any local legal requirements fordisclosure of payments to HCPs/GOs.

oCross Border Engagements. When engaging an HCP/GO to perform services outside of
their primary region of medical practice (or governmental employment) to conduct a service
in another region (e.g., European HCP performing a service in Asia), the BRP and CCO
must approve the engagement. The Teleflex legal entity within the HCPs/GOs primarycountry of medical practice (or governmental employment) will enter into a contract withthe HCP/GO for the cross border engagement. Exceptions to the cross border engagement
contracting requirements must be obtained from regional finance and compliance andappropriately documented.

oContracting. A written contract, signed by both parties, that specifies the services to beprovided is required prior to the provision of services by an HCP/GO. To ensuretransparency into the transaction, documentation is required and must be maintained, even
if compensation is not involved. At minimum, all HCP/GO contracts must include thefollowing: 1) a requirement that the HCP/GO will comply with all applicable laws andindustry codes; 2) nature of services to be provided including scope of work; 3) appropriate
confidentiality provisions; 4) compensation rate consistent with FMV; 5) a requirement thatthe HCP/GO inform their employer, if required by local law; 6) certification that the HCP/GO
is not currently subject to medical discipline or criminal sanction; 7) process for travel
expense reimbursement; 8) disclosure requirement of the HCPs/GOs consultant status
with Teleflex whenever they write or speak in public; and 9) an acknowledgement thatTeleflex may observe or otherwise monitor the services rendered.

oHospitality and Travel Expenses. All hospitality and travel expenses related to HCP/GO
consulting services must meet the following requirements. The BRP will set up processes
to ensure these rules are followed: 1) training and education venues are conducive toscientific interactions; 2) accommodations are reasonable and consistent with local legal
requirements and cultural norms; and 3) strict prohibition of advance payments toHCPs/GOs for arranging their own travel (Teleflex pre-arranging and paying for travel
ahead of time is permitted).

4o•Regional finance should 1) reimburse HCP/GO consulting meal expenses in accordancewith local laws; 2) establish monetary limits for HCP/GO consulting meals in local currency;
and 3) monitor local compliance with such limits. Frequent or repeated violations of theHCP/GO consulting meal limits should be elevated to the BRP and CCO.

Policy #4 – Congresses, Academies, and Trade Shows
oExhibits, Symposia, and General Congress Sponsorships. It is appropriate for Teleflex tosponsor industry held third party events such as congresses, academies, and trade shows.
The BRP must implement a process that ensures the following: The legitimacy of the requesting entity is verified; The budget, sponsorship amount, and any other requested funds are at FMV forthe exposure, advertising, and marketing activities Teleflex receives forparticipating in the event; If required by the local industry code, the event program – rather than the event
location – must be the main draw for the event, and it relates to the specialty and/ormedical practice of the HCPs who attend the event and does not containentertainment; The event topics are of an educational, scientific, or professional nature consistent
with Teleflex’s lines of business. Any event that involves HCPs or GOs which
is wholly or mainly of a social nature is not appropriate for Teleflex
sponsorship or involvement; Event location and venue are appropriate based on the place of residence of themajority of attendees. If required by the local industry code, it must not beperceived as luxury or touristic/holiday- oriented or that of an entertainment venue;
 Teleflex may not directly or indirectly influence the selection of program content,faculty, educational methods and materials or participants attending a third party
educational event; No support can be provided to facilitate the travel of HCPs/GOs spouses or guests
that do not have a bona fide interest in the event; and Any hospitality or travel provided to HCPs/GOs at third party organized events
must be modest and reasonable and expressly allowed under the local industrycode.
Teleflex may purchase satellite symposia packages at congresses and provide approved
presentations on subjects consistent with the overall agenda. In these instances, Teleflex
determines the content of the symposia and is responsible for selecting and engaging aspeaker or speakers. Any speaker’s engagement must be done in compliance with Policy
# 3.

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Sponsorship of HCP Delegates. It is not permissible to provide direct Delegate
Sponsorship of HCPs to industry trade shows, congresses, and academies for
European HCPs (with exception to procedural trainings organized by third parties).

Policy #5 – Samples and Product Evaluations
oGeneral Policy. Teleflex may provide samples to HCPs/GOs free of charge underappropriate circumstances. The BRP and regional finance head must create andimplement a process that ensures the provision of product samples complies with the items
below and appropriately tracks and accounts for all samples.
 Samples are provided to HCPs/GOs that are qualified to dispense the product; The product is appropriately cleared by the regulatory authority in the country
where it is dispensed for use on the market (e.g. FDA).
5oo•The sample is intended only as a benefit to properly qualified indigent patient (i.e.
as part of a charitable donation) or to allow the HCP/GO to evaluate the productfor future use.
Free samples may not be given for an HCP’s or GO’s personal benefit and may
not be given to an HCP for subsequent resale or billing for reimbursement
purposes.

Frequency. Free samples may only be provided to a specific HCP/GO in amounts
reasonably necessary to support patient care, or to permit the HCP/GO to adequately
evaluate the product for future use. The BRP, CMA and regional finance head must
establish reasonable limits (specific number per product type to allow auditing andmonitoring) on free samples in each region and implement a process that appropriately
tracks and accounts for the samples provided to HCPs and GOs.
Capital Equipment or Multiple Use Product Evaluations. All capital equipment placement
and multiple use product evaluations must be placed in accordance to local law andindustry code. Each evaluation must have a written agreement which includes provisions
covering: 1) Teleflex’s continued ownership of the capital equipment or multiple use
product during the evaluation period, 2) the exact number of days in the evaluation periodand; 3) that the HCP/GO is financially responsible for loss and/or damage of the equipment
or product during the evaluation period.

Policy #6 – Market ResearchoGeneral Policy. Market Research must be initiated and conducted in a manner that is notpromotional in nature. Market Research is intended to gather information about a product,disease area, or other topic of interest to Teleflex to be used in future marketing or productdevelopment activities.
 The Market Research activity itself must not be conducted with the intent topromote Teleflex’s product (clarify it is the research itself).
 It may be done in the form of questionnaires or structured interviews (or otherqualified approaches with BRP and CCO approval).
 Market Research must be conducted according to a defined market research planthat describes the objectives and conduct of the research.
 It is permissible to pay HCPs (in local currency) to participate in Market Researchat an FMV rate established by CMA, the regional finance head, and CCO and must
be done in accordance with a written agreement.
 Statistics and data derived from Market Research must be used for marketing
activities and/or promotional content, only in compliance with local applicable lawsand regulations.

oEngaging Third Party Market Research Agencies (“Agency”). The following Policy mustbe followed and implemented by the BRP and regional finance head: Verification that the Agency is reputable.
 A clear task (detailed justification and description of objectives of the MarketResearch) must be provided to the Agency.
 The Agency will select the HCP participants based on criteria provided by Teleflex
and agreed upon by the BRP and CCO. Teleflex will have no additional input in
HCP selection outside of the set list of criteria provided.
 The Agency is responsible for the quality of the questionnaires used in the MarketResearch.
 Teleflex must use the data collected through the Agency for marketing and/or
promotional content, in compliance with local applicable laws and regulations.

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The terms between Teleflex and the Agency must be set out in a written agreement
prior to engagement (which includes the terms detailed under Policy #6). Theagreement must also contain a specific term that requires all payments to HCPs
be paid in accordance with the FMV established by Teleflex and approved by CMA.

Policy #7 – Authorship
oGeneral Policy. Teleflex must review all abstracts, presentations, manuscripts, or otherpublic disclosures pertaining to Teleflex sponsored publications or presentations before
they are made available to the public.

oTeleflex follows the authorship credit criteria laid out by the International Committee ofMedical Journal Editors (“ICMJE”). In order for an HCP to receive authorship credit for apublication related to Teleflex, the BRP will ensure ALL of the following conditions are met: Substantial contributions to conception and design, acquisition of data, or analysis
and interpretation of data; Drafting the article or revising it critically for important intellectual content; and Final approval of the version to be published.

oAcquisition of funding, collection of data, or general supervision of the research group alone
does not constitute authorship (e.g. Teleflex cannot ghost write an article for publicationand give an HCP authorship credit simply because he/she provided the data used in thepublication).

oDisclosure Requirements. Teleflex supports transparency in financial disclosure forpublications. As such the BRP will ensure the following disclosure conditions are met prior
to approving an article, speech, publication, abstract, or public written work for Teleflex:
 For all Teleflex supported studies, the author will disclose at the beginning or endof the publication that financial support was provided by Teleflex.
 All authors will provide all disclosures required by journals, organizations, orcongresses under whose auspices the publication or data will be published orpresented.
 Teleflex employed authors must disclose their employment status.
 If a Teleflex employed author has a specific financial relationship with a productthat is the subject of the publication or presentation that relationship must bedisclosed (e.g. a product manager’s bonus being tied to a specific products
revenue, where that employee also author’s an article about that product).

oTeleflex does not compensate HCPs for authoring abstracts, publications or poster
presentations, in which HCPs would like to remain independent.

Policy #8 – Patient Interactions
oPatient Interactions. Patient interactions are non-promotional activities. Their purpose isto receive knowledge enhancing information (e.g. patient advisory boards) or to obtaininsight into the patient journey (e.g. patient experience events). The ultimate purpose of
all patient interactions is to enable better patient outcomes. The BRP must create a processthat ensures the following safeguards are followed in their region:
Most jurisdictions have very specific laws/rules around direct to consumer
advertising. Therefore, legal and regulatory should be involved in anyreview/approval process at a local level for any direct-to-consumer advertising.

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•Any participation of patients, caregivers, or their physicians must be based on theexplicit consent of the patient, caregiver, or physician involved prior to theirinteractions with Teleflex.
Any participation of a patient in any video, photograph, or service must be basedon a written contract approved by legal regardless of whether compensation isoffered.
Patients can be compensated for the time spent on appropriate Teleflex projects.
The BRP must reasonably define patient compensation and document it locallyprior to any event. No compensation may be offered or provided if it is intended tohave an inappropriate influence on patients.
Teleflex must not in any way influence patient testimony. Freedom of speech isguaranteed.

Policy # 9 – Teleflex Product Training and Medical EducationoGeneral Policy. Teleflex may organize Product Training and Educational Meetings withHCPs so long as the training and education offered through such meetings is provided byTeleflex Associates or Consultants (under written contract with Teleflex) qualified to explain
the appropriate use of Teleflex products and the attendee selection criteria is documented
and approved by CMA. Commercial reasonableness will need to be documented andapproved by CMA for any HCPs attending a Product Training and Education Meetingoutside of their region. It is appropriate to organize Product Training and Educational
Meetings to address:
Training on appropriate use of Teleflex products, consistent with the Teleflex
products’ indications for use approved by the applicable regulatory bodies;
Education regarding how to apply the approved indications and uses of Teleflex
products to the continuum of care (reference to treatment of specific disease statesis allowed only when consistent with approvals issued by the applicable regulatorybodies); andTraining on the qualities, properties, and/or design characteristics of Teleflex
products as related to approved indications for use of such products.

• Policy # 10 Humanitarian Aid and Charitable Donations
oGeneral Policy: Teleflex may make donations of money, products or services to bona fide
non-profit entities, charitable organizations, missions or other organizations supporting
charitable projects or for other philanthropic purposes. Donations cannot be tied to past,present or future use of Teleflex’s products. All requests for donations from the charitableorganizations must be submitted in writing and approved in advance of payment. It is
forbidden to support a charity at the request of an HCP, to target a donation to an HCP, oruse a donation as an encouragement or reward for an HCP using, recommending,purchasing or prescribing Teleflex products

oAppropriate written documentation setting forth the terms and conditions of the donationmust be in place with the requesting charitable organization after the approvals have beenobtained and before the donation is made.

oAll payments/in-kind support must be made to organizations and not individuals.

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Policy #11 Reporting Compliance Concerns
o General Policy: Any person who knows or suspects violations of this Code by any
employee or Third Party working for or on behalf of Teleflex shall report it through one ormore of the following channels:• Regional Compliance Officer• Chief Compliance Officer, VP• Teleflex’s Vice President Internal Audit• Teleflex’s General Legal Counsel• Or through the Ethics Line at www.TeleflexEthicsLine.com
o Available 24/7 and 365 days a year.
o Concerns can be reported anonymously via the internet or on the phone.
o Available in Italian

Neither Teleflex employees, nor its Third-Party Representatives will be subjected to retaliation for goodfaith reports of suspected violations.
Internal processes should be implemented for the following subject matter areas and will be referred to as
Integrity Policies and Procedures (“IPPs”).

1.
2.
3.
4.
5.
6.
7.
8.
9.

Gifts/Educational Items
Business Meals
Educational Grants
HCP Consultant Engagements
Congresses and Trade Shows
Delegate SponsorshipSamples, Demo and Product Evaluations
Market Research
Product Training and Medical Education

Any person who knows or suspects violations of this Code by any Teleflex Associate or third party working
for or on behalf of Teleflex shall report it to the Teleflex Compliance, Legal or Internal Audit departments,
the CCO or the Ethics Line at www.TeleflexEthicsLine.com. Teleflex Associates will not be subjected toretaliation for good faith reports of suspected violations.

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