Global Code of Business Conduct

Medical Device Components LLC

Updated: 24 April 2026

Code of Business Conduct

What is the Medical Device Components LLC Code of Business Conduct?

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.

Anti-Bribery and Anti-Corruption

Medical Device Components LLC (MDC) 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:

• MDC will always uphold the highest standards of integrity and will never be involved in bribery or corruption.

• We treat business partners, competitors, decision makers and other stakeholders with respect.

• We strive to work with third parties who also value and demonstrate high ethical standards in their business practices.

Antitrust and Anti-Competition Laws

MDC 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.

Integrity in our Supply Chain

Anti-Slavery and Anti-Human Trafficking

Conflict Mineral Policy

Public Procurement

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. 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.

Our Commitment to Quality

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:

• Strict Quality Policies and regulatory standards (e.g. ISO and RoHS).

• Proactive risk management and compliance monitoring through audits and inspections.

• Rapid issue escalation and corrective actions to maintain safety and reliability.

• Continuous improvement and training to uphold excellence across all processes.

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.

Export Control

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.

MDC 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 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.

Sustainability and ESG

Sustainability — Overview

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. We follow company-wide policies and adhere to all relevant laws and regulations related to our facilities and the products we manufacture and distribute.

Environmental Social Governance (EH&S) Strategy

MDC integrates EH&S into everyday business decisions to ensure long-term environmental and social responsibility.

Key sustainability efforts include:

EH&S Strategy & Governance: Setting and reviewing long-term ESG goals, integrating sustainability into operations, and collaborating with internal and external stakeholders.

Legal Compliance & Standards: Incorporating global EH&S regulations, implementing best practices, and maintaining applicable ISO and REACH RoHS certifications.

Risk Management & Emergency Preparedness: Identifying and mitigating workplace hazards, investigating incidents, and ensuring rapid emergency response.

Performance Monitoring & Data-Driven Insights: Using predictive analytics to prevent workplace injuries and environmental incidents.

Culture & Training: Fostering a safety and sustainability culture, providing ongoing training, and engaging employees in ESG initiatives.

Sustainable Supply Chain: Assessing and managing supplier EH&S risks and promoting responsible practices throughout our supply chain.

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