GRANT AND CHARITABLE DONATIONS POLICYAND SUBMISSION GUIDELINES

I. Purpose and Scope
MicroPort Orthopedics, Inc. (“MicroPort”) is committed to fostering charitable donations and giving,
and to encourage research and education. This commitment is based on the principles oftransparency and accountability by ensuring compliance with applicable laws and regulations, andpreserving the integrity of the physician-patient relationship. This Grant and Charitable Donations
Policy (the “Policy”) is intended to be consistent with the principles set forth in MicroPort’s Code ofBusiness Conduct, applicable global medical device trade associations codes of practice including,but not limited to, AdvaMed, Medtech Europe, Medical Technology Association of Australia, andAdvaMed China, Accreditation Council for Continuing Medical Education (ACCME) Essentials andStandards for Commercial Support, and state and local laws.
This Policy applies to all Company Representatives, which include all employees (full-time, parttime and temporary), executive officers, members of the Board of Directors, independent contractors,
consultants, sales agents, distributors, distributor employees, sub-distributors and all others
performing services on behalf of the Company.
“Health Care Professionals” (HCPs) include individuals and entities that are (1) involved inproviding health care services and/or items to patients and (2) in a position to purchase, lease,recommend, use, arrange for the purchase or lease of, or prescribe MicroPort’s products. The phrase
HCP is to be interpreted broadly and includes both persons providing services (such as physicians,physician assistants, nurses, operating room staff or consultants) and persons who do not provide
services directly (such as administrative hospital or office staff), but who may be involved in thedecision to purchase, lease, or recommend MicroPort products. HCPs also include purchasing
agents, physician’s practice managers and management within Group Purchasing Organizations(“GPOs”).

II. Eligibility
A. MicroPort will only provide grants and donations to support and encourage:
the advancement of medical science or education. Fellowships based outside the UnitedStates may be directly funded if such programs are accredited under recognized local
standards and are within fair market value for such programs;indigent care or medical missions;patient and public health education; and

events where the proceeds are intended for charitable purposes.

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B. MicroPort will not provide grants or donations:

for research unless there is a written agreement defining the required procedures andprotocol;where the budget for a proposed program appears to be unreasonable under thecircumstances;

to directly fund any fellowships within the United States. Fellowships based in the UnitedStates may be funded through legitimate medical education foundations or institutions;

to non-profit organizations that are controlled, or if there appears to be significant control
by an HCP or an immediate family member of an HCP, or if there appears to be any
inappropriate influence by the HCP on the organization;

to fund scholarships unless the recipients are medical students, residents, fellows, orothers who are HCPs in training;

where the circumstances are likely to improperly influence, or appear to improperly
influence, medical judgment;where one purpose is to influence an HCP to purchase, lease, recommend, use, arrange
for the purchase or lease of, or prescribe MicroPort’s products.

when the funds would be used to defray the requestor’s ordinary operating expenses oroverhead;when funds would pay for travel, housing expenses or time spent for doctors attending
third party educational events;to fund educational events whereby social events or activities such as golf outings, leisuretime, or other recreational activities, take precedence over the educational component andare not considered high quality programs of significant educational value;when the funds would be used to directly fund payments for exhibit space, consulting orother services or goods provided to MicroPort, MicroPort promotional activities or events,
or any program where any of the speakers are MicroPort employees; and

when the funds would be in support of or to offset entertainment or recreational activities.

III. Administration
MicroPort’s Arrangements Review Committee (“ARC”) is the administrative body that reviews andapproves all grants and donations including, but not limited to, research grants, scholarships,
fellowships, education grants, and all other charitable donations to organizations that are affiliatedwith HCPs. The ARC meets at regularly scheduled intervals.

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The Human Resources Department reviews and approves charitable donations to organizations
that are not affiliated with HCPs.
Recipients in the US: Except in the case of medical missions, MicroPort will only award funds to(1) non-profit organizations or (2) entities that have been recognized as qualified providers ofcontinuing medical education (“CME”) by the ACCME, or by state or territory medical societies
approved by ACCME to accredit CME providers.
Except in the case of medical missions, grants and donations must not be provided to: any individual;
any “for-profit” physician practice or group;

any patient;

any individual on behalf of any patient or HCP; or

non-CME accredited “for-profit” providers.

Recipients outside the US: Except in the case of medical missions, MicroPort will only award
funds to a legal entity or body which has a charitable and/or philanthropic purpose.
Except in the case of medical missions, grants and donations must not be provided to: any individual;any Healthcare Organization;

any patient; or

any individual on behalf of any patient or HCP.

Product Donations: MicroPort may donate product for charitable missions and/or the benefit ofindigent patients. Requests for product donations will require certification by the requestor that thepatient‘s physician(s) and/or the hospital or other facilities will not bill the patient, government
healthcare programs, or any other person or third party payor for the cost of any of the health careservices for which donated products will be used.
Any multi-use equipment provided for product donations must adhere to MicroPort’s inventory
controls to assure proper return of equipment (e.g. instrument sets and kits).
Fellowships: MicroPort may provide funds to subsidize accredited fellowship programs by funding
fellows' educational activities and expenses related to disease states treated by MicroPort therapies
and support of post-residency training programs that allow new physicians to continue their training
and specialize in a specialty or sub-specialty. In the United States, these grants may only be provided
to third-party groups that have a bona fide interest in advancing education and research in the areasof legitimate interest to MicroPort.
Educational Grants: MicroPort may provide funds to support HCP participation at third party
educational events as well as support for third party organized educational events. These grants may
only be provided to third-party groups that have a bona fide interest in advancing education andresearch in the areas of legitimate interest to MicroPort. The organization receiving the funds shall beMicroPort Orthopedics, Inc.
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solely responsible for selecting the recipient of the funds. For those events held in Europe, MicroPort
will also be responsible for transparency reporting to Medtech Europe.
Grand Rounds: MicroPort may provide funds to support programs for education offellows/residents/interns. These programs are therapeutic area specific, but not specific to acompany’s product. Company Representatives may not attend Grand Rounds events that MicroPort
has funded.
Exhibits, Booths and Meeting Sponsorships: Exhibits, booths and meeting sponsorships are notconsidered grants or donations and must be approved through MicroPort’s Compliance Department
and/or ARC.

IV. Request Requirements
The Requestor should submit the required documentation, as outlined below, to the MicroPort
grants mailbox at grants@ortho.microport.com. Each request must be received from an authorized
representative of the requesting organization and include the following:
The requestor’s name and addressIRS tax identification number and a copy of the IRS tax-exempt determination letter (orother appropriate tax-exempt status documentation); or legal status for those organizations
outside the US

A letter and a description of the organization’s charitable, educational, or scientificpurpose;A description of the specific educational or charitable event or other purpose for the grant;

A detailed agenda of the event, outlining location, dates, time, speakers and topics;A detailed budget, outlining the event and speaker expenses;

For US companies, a completed W-9, signed by the organization;

For medical missions, a list of the requested products to be provided by MicroPort, alongwith the purpose and ultimate destination for the use of the products; and/or a descriptionof the requested equipment to be provided by MicroPort, along with the purpose andultimate location of the equipment; andCompleted Certification of Compliance from the organization, including confirmation thatrequestors and their respective institutions are not persons or organizations excluded fromparticipation in Medicare, Medicaid, other federal healthcare programs by the Departmentof Health and Human Services Office of Inspector General and are not barred from federal
contracting by the General Services Administration, or public healthcare programs globally.
In the case of fellowships, these requirements are also applicable to the attending
physician and the proposed fellow. See Appendix A for a copy of the Compliance
Certification.

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Funds must be paid directly to the recipient only by MicroPort check or electronic funds transfer.

V. Grant Review Process
Upon receipt of the grant request by MicroPort, the Grant Requestor will receive confirmation of
the request by email.
The Requestor will receive written notification of MicroPort’s decision upon completion of thisreview. MicroPort reserves the right to deny a grant or charitable donation request for any or noreason, in its sole discretion. MicroPort is under no obligation to provide an explanation for its
decision.
To avoid delays and ensure a complete evaluation process, requests should be submitted at least
12 weeks prior to the event for which funding is being requested and should contain the required
documentation as stated above.
Revised: August 30, 2017
Effective: April 15, 2015
CMPL000022 – Rev. 04

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MicroPort Orthopedics, Inc.
Certificate of ComplianceThis certification is intended to comply with all applicable laws, rules and regulations regulating thesubject matter of this request for funding and the relationship to the parties, including the federal antikickback statute 42 U.S.C. §1320a-7(b), as well as the related safe harbor regulations. MicroPort
reserves the right to modify this certification for such reasons as MicroPort deems appropriate tomaintain compliance with federal, state, local laws, rules, and regulations.
I, the undersigned, certify that to the best of my knowledge, all of the following statements are true
with respect to this request:
1. The receiving organization, its personnel, and I have not, implicitly or explicitly, solicited therequested donation in exchange for an agreement to purchase, use, order, or recommend MicroPort
products.
2. No representative of MicroPort Orthopedics implicitly or explicitly offered a donation to thereceiving organization, its personnel, or me to purchase, use, order, or recommend MicroPort
products or to reward prior purchases, uses, orders, or recommendations of MicroPort products.
3. The requested donation will not result in any private benefit to a health care provider who uses,orders, or recommends MicroPort products.
4. The receiving organization, its personnel, and I are not a person (or persons) or organization
excluded from participation in the following US programs or other Public health systems, globally:Medicare, Medicaid, or other federal healthcare programs by the Department of Health and Human
Services Office of Inspector General and is not barred from federal contracting by the General
Services Administration.
5. The receiving organization, its personnel, and I are not a person (or persons) or organization
identified on the U.S. Treasury Department’s list of Specially Designated National or Blocked Persons.
6. The receiving organization, its personnel, and I have read and accept MicroPort Orthopedics
Code of Business Conduct.
7. The services provided under this requested donation will not be billed to patients and thirdparties.
Organization Name:____________________________________________________________
Requestor’s Name & Title:_______________________________________________________
Area Code & Phone Number:_____________________________________________________
Signature:____________________________________ Date:___________________________
If you have any questions about this Certificate, please notify MicroPort Orthopedics’ Compliance
Office by sending an email to grants@ortho.microport.com.