To our knowledge as of the date of this declaration, Micrus Endovascular, LLC is in compliance with our Comprehensive Compliance Program, as described here, and with California Health & Safety Code sections 119400-119402.
 
Dated: July 1, 2011
 
NOTICE: this information is provided pursuant to the requirements of Cal. Health & Safety Code § 119402 (S.B. 1765), which requires certain pharmaceutical and medical device companies doing business in California to make available their program for compliance with applicable federal and state laws and industry standards regulating the marketing and promotion of their products.
 
I. Introduction
 
Micrus Endovascular, LLC has established a program designed to materially comply with applicable federal and state laws and industry standards relating to the marketing and promotion of its products. Additionally, Micrus Endovascular, LLC recognizes that adherence to these standards can be furthered through a compliance program that is informed by the Compliance Program Guidance for Pharmaceutical Manufacturers, published by the Office of Inspector General of the U.S. Department of Health and Human Services (the “OIG Guide”). The OIG Guide advises that effective compliance programs are comprised of seven elements. As described below, these elements form the basis of Micrus Endovascular, LLC’s program for compliance with the standards regulating the marketing and promotion of its products.
 
II. Overview of Compliance Program
 
Written Policies and Procedures
 
Micrus Endovascular, LLC has written policies to promote compliance with the applicable laws and regulations and standards governing the marketing and promotion of our products. Among these standards are recognized industry codes of conduct including the Code of Ethics on Interactions with Health Care Professionals (AdvaMed Code), published by the Advanced Medical Technology Association (“AdvaMed”). Micrus Endovascular, LLC has established written policies that govern activities involving communicating with customers about the appropriate use of our products including appropriate instruction, education, training, service and technical support required for the safe and effective use of our products. Micrus Endovascular, LLC also has policies governing activities involving the advancement of scientific and educational activities supporting medical research and education. These policies include:
 
Policy on Educational Grants and Research Grants
 
Micrus Endovascular, LLC may provide grants for specific educational purposes that benefit patients and customers. These may include, but are not limited to, continuing medical and paraprofessional education programs, fellowships provided to teaching institutions and similar organizations with a demonstrated commitment to scientific and technical education, and programs operated by organizations that provide high-quality, nationally recognized patient education. Funding of educational programs will generally be provided only to organizations and institutions and not to individual practitioners.
 
Research grants to support customer-initiated research may be provided for programs involving research in areas of legitimate interest to the company. All requests are subject to scientific review prior to funding approval.
 
Policy on Travel Expense Reimbursement for CME, Promotional or Product Training Meetings
 
Micrus Endovascular, LLC will, with very limited exceptions for health care professionals in training, which complies with the AdvaMed Code, not reimburse for travel and lodging expenses of attendees at promotional and educational programs.
 
Micrus Endovascular, LLC may reimburse attendees for their reasonable travel and lodging expenses associated with attendance at product training meetings. Product training meetings will be conducted in locations conducive to the exchange of information such as educational or conference settings. Where face-to-face or hands-on customer training is reasonably necessary for the safe and effective use of Micrus Endovascular, LLC’s medical device products is required, Micrus Endovascular, LLC may provide training at company facilities, at independent teaching centers such as medical institutions, or in other appropriate clinical settings.
 
Policy on Business Meals
 
Micrus Endovascular, LLC may occasionally provide a modest meal, consistent with the standards of the AdvaMed Code as part of an educational presentation or a business discussion. Venues that feature entertainment or recreation, and attendance by spouses or guests, are not permitted. The cost of meals with customers should not exceed $35 for breakfast, $50 for lunch or $125 for dinner.
 
Policy on the Provision of Educational and Practice-Related Items
 
On occasion, Micrus Endovascular, LLC representatives may provide items that benefit patients or serve a genuine educational function for Health Care Professionals, consistent with the standards of the AdvaMed Code.
 
Micrus Endovascular, LLC has established an annual limit of $1500 for meals and educational items as the aggregate value of the items or activities that may be provided to California health care professionals pursuant to the requirements of Cal. Health & Safety Code § 119402 (S.B. 1765).
 
Policy Prohibiting Entertainment
 
It is the policy of Micrus Endovascular, LLC not to provide Entertainment (e.g. sporting events, golf outings, concerts, hunting, etc.) to customers.
 
Assigned Compliance Officer
 
Micrus Endovascular, LLC has appointed a Health Care Compliance Officer. Our Health Care Compliance Officer has been empowered with appropriate authority to exercise independent judgment and has free and unencumbered access to senior management.
 
Micrus Endovascular, LLC has appointed a Health Care Compliance Committee. The committee is comprised of the company’s Health Care Compliance Officer and members of the company’s management team. The Health Care Compliance Committee is the Health Care Compliance leadership team.
 
Training
 
Micrus Endovascular, LLC has an annual Health Care Compliance training process that includes an assessment and annual certification of appropriate employees and sales associates. The training covers applicable guidelines governing our compliance program. Employees and sales associates are also trained on the consequences of failure to comply with the requirements of the company’s compliance program.
 
Communication
 
Micrus Endovascular, LLC encourages open and candid discussion between management and employees regarding any compliance concerns. Micrus Endovascular, LLC employees are encouraged to report their concerns to their manager, to the Human Resources Department, to the Law Department or to the company’s Health Care Compliance Officer.
 
Auditing and Monitoring
 
Micrus Endovascular, LLC self-assesses and periodically audits its compliance with its policies and procedures.
 
Enforcement and Disciplinary Guidelines
 
Micrus Endovascular, LLC will take disciplinary actions in response to violation of the company’s compliance policies or procedures. Micrus Endovascular, LLC will conduct a fair and diligent investigation of matters that are brought to the company’s attention in order to ensure the consistent application of the company’s standards.
 
Responses To Detected Problems and Actions To Correct Issues
 
Micrus Endovascular, LLC requires a prompt and diligent response to potential violations of the company’s compliance program, including its standards regulating the marketing and promotion of our products. Actions in response to detected problems may include improving policies, procedures, training, communication and monitoring or may require disciplinary action to prevent future violations.
 
For a copy of the above Micrus Endovascular, LLC California Compliance Program, please call our toll free number, (800) 852-4382. Leave a voicemail clearly stating your name, mailing address, and a copy of the program will be sent as you requested.