The fundamental elements of our compliance program are described below. Note that our compliance program is constantly evolving to meet the changing needs and demands of the compliance environment and of Boston Scientific. We continuously review and enhance our compliance program, and reserve the right to continue to do so at any time in the future without notice.

• Leadership: Boston Scientific’s Global Compliance program is led by our Senior Vice President and Chief Compliance Officer. The Chief Compliance Officer makes periodic reports to the audit committee of Boston Scientific’s board of directors. This officer also chairs our Compliance Steering Committee, which provides strategic direction and oversight regarding the implementation of our global compliance program.
• Written Standards: Our Code of Conduct is a cornerstone of our compliance program, and provides guidance on business conduct and practices to all Boston Scientific team members. While the implementation of a compliance program cannot guarantee that all improper employee conduct will be eliminated, it is Boston Scientific’s expectation that each of our team members will comply with our Code of Conduct, and the policies that have been established in support of that code.
• Communication: Boston Scientific is committed to fostering effective lines of communication between management and employees. Employee training and education programs increase awareness of the legal and ethical implications of abiding by our Code of Conduct and related policies, and making sound and ethical business decisions. We monitor the nature of inquiries that our compliance program receives and make appropriate adjustments to our training and communications.
• Getting Advice and Reporting. Boston Scientific provides a number of resources that employees and others can use to ask a question, obtain guidance, or report a Code of Conduct concern. Boston Scientific strongly encourages use of these resources. One of the resources for reporting concerns is our Advice Line, a toll-free telephone number that anyone can call, 24 hours per day, seven days per week. The Advice Line handles calls in multiple languages. The toll-free number is 888-968-8425.
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• No Retaliation: Boston Scientific Boston Scientific does not tolerate any form of retaliation against an individual arising from a good-faith report of a potential violation of our Code of Conduct, a related policy, or of an integrity concern. Retaliation is also prohibited against anyone who participates in an investigation of such a report.
• Monitoring and Auditing. Boston Scientific’s compliance program includes ongoing efforts to monitor, assess and audit compliance with our Code of Conduct and related policies. Our compliance program has a dedicated group that conducts both cause and risk-based audits and also works with our internal financial audit function, to monitor compliance, identify potential problem areas, and support preventative measures and corrective actions.
• Responsiveness:Boston Scientific responds promptly and impartially to questions, concerns, and reports of potential violations of our compliance program. We have implemented policies and processes for the prompt and proper investigation of such reports.
• Corrective Action: Boston Scientific’s compliance program includes clear policies that set out the consequences of violating the law, our Code of Conduct and related policies. Although each situation is considered on a case-by-case basis, Boston Scientific consistently undertakes appropriate corrective action to address inappropriate conduct and to deter future violations.