Business Courtesies (Meals and Hospitality)
We may provide attendees with reasonably priced meals and refreshments when necessary for a legitimate business purpose, such as in connection with bona fide educational / scientific programs. Unless prohibited or further restricted by state law or an HCP’s employment rules.
• Meal Limits: USD 100 per HCP per meal
• USD 500 per HCP per calendar year (exclusive of tax and tips)
• Invitations of HCPs guests / spouses who do not have a legitimate business interest are prohibited.
We do not provide or pay for entertainment, such as sporting, cultural, touristic and/or other pure leisure activities, for anyone whether Government Official or other, private business partner.
Gifts and Contest Prizes
We may occasionally provide inexpensive, branded, or non-branded items to HCPs, if they are nominal in value, provided only infrequently and in compliance with the laws of the state in which the HCP is licensed to practice. Unless prohibited or further restricted by state law or an HCP’s employment rules.
“Nominal” is no greater than USD 10 per item and the aggregate value not greater than USD 50 per year.
Demo / Loaner Equipment (i.e. loan of physical asset)
Loans of physical assets, such as demo equipment, for evaluation and demonstration as well as for research purposes may only be provided pursuant to a written loan agreement reviewed, approved, or drafted by the Legal Department and which is executed prior to shipment of demo or loan equipment.
Customer Rebates / Discounts
Rebate / discount programs must be reviewed by Legal and Compliance before implementation.
Consulting or Other Agreements
HCPs may serve as consultants providing meaningful bona fide services, including research, company-sponsored trainings, and other services, with appropriate and approved legal agreement in place.
Certain other agreements may be entered into with HCPs provided the arrangement is documented with a written agreement that complies with applicable healthcare fraud and abuse laws and regulations.
Company-Sponsored and Company-Organized Events
Training and education programs such as hands-on” training sessions, temporal bone labs, workshops, lectures and presentations must adhere to the Global Antibribery Policy (located on the Sonova Intranet).
Research / Educational Grants & Sponsorship
Grants and sponsorship must be documented and tracked handled in accordance with Global Antibribery Policy. Payments must be properly documented & approved in accordance with Delegation of Authority.
Charitable donations must be in accordance with Global Antibribery Policy and under applicable laws and regulations. All donations must be motivated only by purely bona fide charitable purposes and appropriately documented. Donation payments must be approved in accordance with the Delegation of Authority.