We have established anti-bribery and anti-corruption policies and procedures that cover, among other things, interactions with healthcare providers and government officials. These policies and procedures are reinforced by a robust, interactive, annual training program as well as periodic auditing and monitoring. Zimmer Biomet has a zero-tolerance policy when it comes to bribery and corruption. Zimmer Biomet’s Global Third-Party Compliance team supports and monitors business partners, such as distributors, to help ensure they adhere to the same ethical standards as our team members. Zimmer Biomet also performs anti-corruption due diligence prior to engaging a third party, and periodically during the course of our relationship with a third-party, in addition to third- party compliance audits. In 2021, we introduced a new due diligence platform that provides improved real-time visibility of the due diligence process, a more user-friendly interface and enhanced reporting capabilities. Zimmer Biomet also has a dedicated global compliance investigations team staffed by experienced anti-corruption investigators who manage and conduct all compliance investigations. Whistleblower Program Team members, business partners, customers and members of the public are encouraged and empowered to speak up when they become aware of behavior that may be in violation of Zimmer Biomet’s policies, applicable laws, or industry practices. Every team member and business partner has a responsibility as outlined in the Code of Business Conduct and Ethics to be a voice of integrity. In 2021, Zimmer Biomet introduced the new “Speak Up Hotline” where concerns can be raised confidentially or anonymously, 24 hours a day, seven days a week. The “Speak Up Hotline” replaced a prior compliance hotline platform that had been utilized for many years. Team members can use the hotline to report any concern about a known or potential violation, concerns about safety in the workplace, potential discrimination or harassment, unethical behavior by another team member or a third- party vendor or distributor, falsification of documents or misuse of Zimmer Biomet resources. In addition to the “Speak Up Hotline”, concerns can also be raised directly to managers or Compliance or HR business partners. Zimmer Biomet prohibits retaliation against anyone who makes a good faith report of a known or suspected compliance or legal issue. Retaliation in any form is unacceptable and not tolerated. Our Compliance team tracks and oversees all reported concerns from investigation to resolution. We have instituted a robust and rigorous remediation process to ensure appropriate corrective actions are implemented following all substantiated investigations, such as team member separations, documented warnings and retraining. The Hotline Investigations Steering Committee guides and ensures consistent disciplinary decision-making of these actions. In addition, the Audit Committee of our Board of Directors receives frequent reports on hotline complaints, investigations and corrective actions. In 2021, there were more than 90 compliance concerns reported and investigated. We had 100% completion of all remediation activities arising from these compliance investigations, in addition to audits and monitoring. 100 % COMPLETION REMEDIATION ACTIVITIES 22
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