.png)
Medical Device Components and Lighteum Rebrand as Lighteum Medical
Read More.png)
Our Mission and Values define who we are; our Code of Business Conduct is the guiding framework that ensures we uphold them in every decision we make.
This Code establishes the core principles that shape our business practices and serves as the foundation for our company’s policies, procedures, and guidelines. It provides clear direction on the standards we uphold and the ethical responsibilities we embrace—ensuring that integrity, accountability, and excellence remain at the heart of everything we do.
To uphold our reputation as a company dedicated to improving lives across the globe, each of us must commit to learning, understanding, and adhering to our Code of Business Conduct. Following our Code isn’t just about compliance—it’s about fostering a culture of integrity, transparency, and accountability. By doing so, we create an environment where we can perform at our best, innovate responsibly, and take pride in the way we navigate challenges and achieve success—always with ethics and excellence at the forefront.
All employees of Medical Device Components family of Companies are required to understand and comply with the Code of Business Conduct, Company policies and laws that govern our activities.
When we become aware of a violation of our Code of Business Conduct, company policies, or the law, we take immediate action to address the issue and prevent future occurrences. Depending on the circumstances, corrective and preventive measures may include additional training, counseling, strengthened controls, or disciplinary actions, up to and including termination of employment.
Each of us has a responsibility to SPEAK UP when we encounter or become aware of a situation that may violate our Code, company policies, or the law. Our Escalation Procedure ensures that serious concerns, including potential policy violations or legal matters, are reported through the appropriate channels. Employees should report such concerns directly to those individuals listed in Section 3.2 of our Global Speak Up Policy.
At Medical Device Components, we believe that leadership is not defined by title or role—every employee has the power to lead through their actions, decisions, and commitment to integrity. By upholding our Code of Business Conduct, each of us sets an example for our colleagues, business partners, customers, and all those who interact with us daily.
For people managers, this responsibility extends even further. People managers are expected to lead by example in every aspect, fostering a culture of ethical decision-making and guiding employees in understanding, applying, and upholding our Code in their daily work.
Together, we create a workplace where trust, accountability, and excellence define who we are.
Medical Device Components maintains a firm commitment to ethical business practices, strictly opposing corruption and bribery in accordance with anti-bribery and anti-corruption laws worldwide. We expect the same high standards from our business partners.
We explicitly prohibit bribes, fraudulent activities, kickbacks, illegal payments, or any other exchanges of value intended to improperly influence or secure an undue advantage with government officials, healthcare professionals, or customers. Our organization engages in a wide range of customers. Additionally, we may be required to interact with government regulators, non-governmental organizations, and inspection authorities. Therefore, it is our responsibility to comply with all applicable local and international laws and ethical standards that prohibit bribery and corruption while ensuring that purchasing choices made by entities procuring our products and services remain unbiased.
Any value transfers to third parties must reflect fair market value for services rendered and be based on a legitimate need for the goods or services.
Where and with whom we conduct business may vary, but our approach is consistent:
Medical Device Components is committed to upholding fair competition and complying fully with all applicable antitrust and competition laws. These laws are designed to promote open and fair markets while protecting consumers from unfair business practices. They prohibit unlawful agreements between companies, such as price fixing, and prevent anti-competitive business practices, including predatory pricing.
As a manufacturer of medical device components, we are responsible for conducting business with integrity and fairness when dealing with customers, suppliers, competitors, and other third parties. We strictly adhere to legal agreements with competitors and avoid any business practices that could be considered an abuse of market position. For any questions regarding antitrust and competition laws, please contact the Global Legal Organization.
At Medical Device Components, we are committed to fostering a workplace that is: DIVERSE, INCLUSIVE and EQUITABLE. We stand by our workplace being an environment that values the power of people.
Our culture is rooted in ethical behavior, respect, and integrity. By upholding the highest standards of integrity, we demonstrate our dedication to those we serve and show respect for the individuals we collaborate with. A diverse, engaged, and high-performing workforce helps us better understand and meet the needs and challenges faced by our patients, customers, healthcare professionals, and communities. We believe that every employee deserves to be treated fairly, with respect for their contributions.
Our company provides equal employment opportunities and ensures reasonable accommodations for individuals with disabilities or specific needs related to religious observance. Employment decisions at Medical Device Components are based on merit, including qualifications, skills, and achievements. We do not tolerate discrimination based on personal characteristics such as age, gender, race, ethnicity, sexual orientation, gender identity, national origin, religious beliefs, or union membership. Harassment or bullying in any form will not be tolerated.
We are committed to maintaining a safe, healthy, and supportive work environment for all employees, contractors, and visitors. This includes protecting physical safety in the workplace, supporting psychological well-being, and taking proactive steps to prevent stress and overwork. Everyone shares responsibility for health and safety by promptly reporting unsafe conditions, accidents, or incidents, and by adhering to company policies and all applicable regulations.
Child labor, human trafficking, and any form of illegal, unsafe, or abusive labor practices are strictly prohibited in our operations and those of our suppliers and third-party vendors.
We enforce compliance with local laws and regulations, and we hold our partners to high standards that reflect our commitments to ethics, labor rights, human rights, and employee health, and well-being.
It is Medical Device Components goal to ensure employee voices are heard. Medical Device Components reviews employee-feedback via a periodic anonymous survey, and via our company “Speak-Up” tool Syntrio. We are committed to evaluating all employee feedback and implementing improvements to our business as-feasible.
Drug, alcohol or other substance abuse is strictly prohibited and will be subject to immediate termination.
The principles outlined in this Fair Treatment of Employees section of the Code of Conduct apply to our interactions with employees, customers, contractors, suppliers, and applicants, and in all situations where our employees represent Medical Device Components. We are dependent on our people to uphold our culture our values and to speak up if interactions are observed that do not align with our principles.
Medical Device Components Speak Up Resources:
Alternatively, you can speak up and report any violation to your manager.
Note: Retaliation or threats against anyone who raises a concern under this Code of Conduct or assists with an audit or investigation will not be tolerated. Employees engaging in such behavior will face disciplinary action, including possible termination.
At Medical Device Components, we rely on company assets to support our daily work. These assets include computers, mobile devices, company provided hardware and software, facilities, machinery, raw materials, inventory, intellectual property, supplies, and data. It is our responsibility to use these resources lawfully and appropriately while taking necessary steps to protect them. When handling company information or using technology tools such as laptops, email, applications, and databases, employees must only download and use company-approved software and applications. Strong, complex passwords should be created and never shared. Additionally, company information should not be stored on unauthorized internet or cloud services or non-approved devices that may lack proper security and could be accessed by unauthorized individuals.
At Medical Device Components, we depend on company assets to carry out our work efficiently and securely. These assets include computers, mobile devices, company provided hardware and software, facilities, machinery, raw materials, inventory, intellectual property, supplies, and data.
It is critical that the resources provided and made available by Medical Device Components while doing business are used responsibly, lawfully, and solely for appropriate business purposes while ensuring their protection. Employees must take proper precautions when handling company information and technology tools, such as laptops, email, applications, and databases. Only company-approved software and applications should be downloaded and used. Strong, complex passwords must be created and kept confidential. Additionally, company information should never be stored on unauthorized cloud services or personal devices that may not have adequate security measures, as this could lead to unauthorized access.
For questions related to software, or cloud-based applications, please reach out to Medical Device Components Information Technology (IT) Help Desk at: support@medicaldevicecomponents.com
Employees must follow all company policies when using social media, ensuring compliance with job-related and personal communications that may impact the company. Modeling respectful interactions online is critical as online conduct reflects on our company and its values. Employees may share publicly available company content but must disclose their affiliation using the hashtag “#iworkformdc” and follow reporting obligations, including adverse event reporting.
With advancements in digital technology and the growing importance of data in medical innovation, it is essential to ensure transparency in how personal information is collected, used, and protected. Individuals must trust that their data, especially health-related information, is handled securely and responsibly in compliance with applicable laws and regulations.
As a leader in medical device components, we collect and process personal information from employees, and business partners. This data helps us meet regulatory and contractual obligations while driving innovation in medical technologies. Given the sensitivity of the data we collect, we are committed to lawfully safeguarding personal information and upholding privacy expectations.
In the course of conducting business, we collect and store personal information from employees, business partners and other stakeholders. This data may include contact details, financial information, medical records, and other relevant information. All personal information is collected and processed in compliance with local applicable laws Medical Device Components privacy and data protection policies. Personal information should only be gathered for legitimate business purposes, shared exclusively with authorized individuals, safeguarded in accordance with security policies, and retained only for as long as necessary. Additionally, any third parties granted access to personal information must be contractually obligated to protect it in accordance with applicable data security standards.
We ensure that all personal data is collected only for legitimate business and regulatory purposes and that personal data is only used transparently and securely, with appropriate safeguards in place. We only share personal data with authorized individuals or partners who comply with applicable data security standards and laws. Such data is stored and retained in compliance with applicable laws and company policies.
We continuously monitor privacy regulations and update our practices to maintain compliance, protect individual rights, and support advancements in medical technology while ensuring trust and security in data handling.
At Medical Device Components, a conflict of interest arises when a person or organization has competing interests—financial or otherwise—that could compromise an individual’s ability to make objective decisions. When one interest takes priority, it may negatively impact other responsibilities or obligations.
A personal conflict of interest occurs when personal relationships or activities influence an employee’s judgment, affecting their ability to perform their job objectively. Even the appearance of a conflict of interest can put the company at risk. Employees must ensure that personal gain or divided loyalties never interfere with acting in the best interests of the company and the customers we serve.
An organizational conflict of interest can arise when our company has relationships with entities such as government agencies, healthcare providers, or payor groups that could create a bias in favor of the company. For example, conflicts may occur if we collaborate on developing products while also seeking to sell products or services to the same entities. Additionally, if the company gains access to sensitive government or competitive information and uses it to gain an unfair advantage, this will constitute a conflict of interest.
Maintaining transparency and acting with integrity is essential to upholding our company’s reputation and commitment to ethical business practices.
Determining whether an activity creates a conflict of interest is not always straightforward. However, it is the responsibility of every employee to disclose any potential conflicts, whether personal or organizational.
Employees are expected to discuss any possible personal conflicts—or concerns about situations that may create a conflict—with their manager or a representative from Human Resources.
If a conflict or potential conflict is identified, the discussion should be properly documented to ensure transparency and protection for both the employee and the company.
For organizational conflicts of interest, employees should consult with the appropriate compliance or legal representatives to ensure that the company maintains ethical and fair business practices. Open communication and proactive disclosure help uphold our commitment to integrity and accountability.
Our suppliers, vendors, and business partners play a key role in our success. To ensure fairness and integrity, we avoid conflicts of interest in all business interactions.
Conflicts of interest arise when employees accept gifts, payments, loans, or other benefits from suppliers, customers, or competitors that could influence their decisions. Employees may only accept modest, non-cash gifts, entertainment, or hospitality if they do not impact business judgment.
Always report potential conflicts of interest to a manager.
We strictly prohibit human trafficking and forced labor in our operations and supply chain. This includes sex trafficking, forced labor through fraud or coercion, and any form of labor obtained through threats or exploitation. We also prohibit unethical recruitment practices, withholding of identity documents, deceptive hiring, illegal recruitment fees, substandard housing, and failure to provide required employment contracts.
Violations will result in disciplinary action, including termination of employment or business relationship. We comply with customer and government audits and require employees, contractors, and partners to report any suspected violations immediately. Protecting human rights is fundamental to our business.
We are committed to responsible sourcing and ensuring that minerals used in our medical device components do not contribute to human rights abuses. In compliance with U.S. regulations, we conduct due diligence on the origin of tin, tungsten, tantalum, and gold (3TG) to prevent supporting armed groups in the Democratic Republic of Congo and adjoining regions. Our approach includes working with suppliers to source responsibly, verifying smelters and refiners, and requiring proper documentation of mineral origins. Non-compliant suppliers must take corrective action or risk termination. We also support industry initiatives to eliminate conflict minerals from global supply chains.
Medical device manufacturers and government entities are key customers in the medical device industry. Many countries have strict laws governing how public institutions purchase products and services, and we must fully comply with these regulations. Employees involved in bidding, contracts, or sales to public authorities must understand and follow public procurement rules. These regulations can be complex but are essential to our business. There must be no improper attempts to influence decisions or provide inappropriate benefits to government officials. For guidance on public procurement laws, consult Medical Device Components Legal Team at legal@medicaldevicecomponents.com.
Our company relies on various goods and services to support our operations. When selecting vendors, suppliers, and service providers, we must remain impartial and follow established procurement policies.
Employees must adhere to company guidelines when making purchasing decisions and avoid conflicts of interest. For guidance on accepting gifts, entertainment, or managing personal relationships with vendors and suppliers, refer to the Conflicts of Interest section of the Code.
Quality is essential in medical device components, ensuring the safety of our customers’ patients and regulatory compliance. By integrating quality into every stage of production, we enhance efficiency, reduce risks, and build trust with our partners.
We have implemented:
Employees play a key role by adhering to policies, participating in training, and prioritizing quality.
By maintaining rigorous quality standards, we ensure the reliability of our medical device components, safeguarding the health of our customers’ patients while fostering innovation and efficiency.
Medical device component manufacturers must comply with international sanctions and export control regulations to ensure that products, technology, and services are not supplied to restricted entities, countries, or individuals.
Compliance with international regulations such as the U.S. Export Administration Regulations (EAR), and the Office of Foreign Assets Control (OFAC) sanctions is critical to preventing unauthorized exports or re-exports of controlled items.
Medical Device Components is committed to conducting thorough due diligence, including screening customers, suppliers, and partners against government watchlists and ensuring proper export licensing when required. Additionally, our business has established internal controls, which maintain accurate records, and provide employee training to mitigate risks of non-compliance.
Violations of export control regulations can result in severe penalties, including fines, loss of export privileges, and reputational damage, making strict adherence essential for legal and ethical business operations.
Our belief is that we must maintain in good order the property we are privileged to use, protecting the environment and natural resources.
Guided by this principle, we continuously work to reduce the environmental impact of our operations, products, and supply chain while managing environmental risks. Employees must follow company-wide policies and adhere to all relevant laws and regulations related to their work, facilities, and the products we manufacture and distribute.
Medical Device Components integrates EH&S into everyday business decisions to ensure long-term environmental and social responsibility.
Key sustainability efforts include:
