Compliance Held to the Highest Standard

Total Surgical supplies products and may provide operational, educational, or reimbursement-related support within lawful and clearly defined boundaries. Total Surgical does not practice medicine, direct patient care, or replace the independent judgment of a licensed healthcare professional. Diagnosis, medical necessity, product selection, ordering, treatment, clinical documentation, and patient-specific decisions remain the responsibility of the treating practitioner.

Total Surgical does not offer or provide remuneration to induce or reward referrals, orders, purchases, or other business reimbursable by a federal or state healthcare program. We do not guarantee coverage or payment, and we do not encourage inaccurate, incomplete, misleading, or unsupported claims. Product information and reimbursement resources must be accurate, appropriately qualified, and used in a manner consistent with each provider’s independent obligations.

Total Surgical’s Compliance Program incorporates the recognized elements of an effective compliance program and applies them in a manner appropriate to a wound-care product vendor:

• Written standards and procedures.

  Our Code of Ethics and Business Conduct, compliance manuals, handbooks, and stand-alone policies establish expectations for lawful and ethical conduct.

• Compliance leadership and oversight.

  Designated compliance leadership has authority to administer the program, receive concerns, escalate significant matters, and report to appropriate Company leadership and oversight bodies.

• Education and training.

  Personnel receive orientation and periodic, role-based training addressing the laws, policies, and risks relevant to their responsibilities.

• Open communication and reporting.

  Total Surgical maintains channels for personnel and others to raise questions or report concerns in good faith without fear of retaliation.

• Accountability and consistent enforcement.

  Compliance responsibilities are enforced through appropriate incentives and disciplinary standards, applied fairly and consistently.

• Risk assessment, auditing, and monitoring.

  Total Surgical periodically evaluates its activities, financial relationships, business partners, and operational controls to identify and address areas of elevated risk.

• Response and corrective action.

  Potential misconduct is assessed promptly and objectively. When warranted, Total Surgical investigates, remedies harm, strengthens controls, returns overpayments or makes required disclosures, and takes other corrective action appropriate to the circumstances.

To promote our Compliance Mandate and the elements of a proper Compliance Program, we have implemented handbooks, manuals, and other policies and compliance practices, including adoption of our Code of Ethics and Business Conduct (“Code”). The Code applies to all Total Surgical personnel, contractors, vendors, suppliers, and officers and is designed to provide our representatives with guidance regarding compliance with laws, regulations and Total Surgical policies. We regularly communicate with our personnel regarding the Code to ensure familiarity and awareness and we require that our personnel annually certify their agreement to abide by state and federal laws and our policies (their “Acknowledgments”/“Certifications of Compliance”).

The Code and stand-alone policies also contain specific anti-retaliation provisions intended to protect employees who step forward and “Speak Up!” We explicitly encourage open communication, and we are committed to protecting anyone providing a good faith report of inappropriate business practices or any Misconduct. Retaliation against anyone making a report or participating in an investigation will result in disciplinary action.

Separate from the Code, we provide our workforce with ongoing training targeted to their roles and functions. Training may be provided in person or online and address topics such as anti-kickback, false claims, stark, improper inducements, and other laws and further cover conflicts of interest, privacy, anti-discrimination, anti-corruption and guidelines with regard to, for example, gifts and hospitality to patients. Completion of required training is tracked and refreshed on a regular basis. We also require periodic certifications by management level employees regarding adherence to Company policy and various compliance topics. These practices act to supplement the Code and provide topic specific guidance to employees.

The Code applies to Total Surgical’s directors, officers, employees, and other workforce members. Relevant compliance expectations are also incorporated, as appropriate, into Total Surgical’s relationships with contractors, consultants, vendors, suppliers, and other business partners. Our standards address, among other things:

• Lawful financial relationships.

  Discounts, rebates, fees, marketing arrangements, and other transfers of value must be documented, commercially reasonable, transparent where required, and structured to comply with applicable fraud-and-abuse laws.

• Accurate communications and reimbursement support.

  Product, coverage, coding, billing, and reimbursement information must be truthful, current to the extent represented, appropriately sourced, and never used to override a provider’s independent judgment or claims responsibility.

• Product integrity and responsible distribution.

  Total Surgical expects appropriate sourcing, handling, storage, traceability, complaint escalation, and cooperation with applicable quality and safety requirements.

• Privacy, confidentiality, and security.

  Personal, health, business, and other confidential information must be accessed, used, disclosed, retained, and protected only as permitted by law, contract, and Total Surgical policy.

• Conflicts, gifts, and business courtesies.

  Actual or potential conflicts must be disclosed and managed, and gifts, meals, entertainment, travel, and other courtesies may never be used to influence clinical or purchasing decisions improperly.

• Responsible business partners.

  Total Surgical conducts risk-based due diligence and screening, including applicable exclusion and debarment checks, and expects cooperation with compliance requirements and investigations.

Total Surgical encourages questions and good-faith reports of suspected misconduct, policy violations, unsafe practices, inaccurate representations, conflicts of interest, privacy or security concerns, and other compliance issues. Concerns may be raised through Total Surgical’s designated compliance reporting channels. Total Surgical will protect confidentiality to the extent reasonably practical and permitted by law and will not tolerate retaliation against anyone who makes a good-faith report, seeks guidance, or participates in a compliance review or investigation.

Reports are assessed and, when appropriate, investigated by qualified personnel with attention to independence, fairness, documentation, and timely escalation. Substantiated violations may result in corrective action, discipline up to and including termination of employment or a business relationship, repayment or disclosure obligations, and referral to governmental authorities when appropriate.

Compliance is a continuing responsibility. Total Surgical uses risk assessments, monitoring, audits, training results, reports, investigations, corrective actions, and changes in law or operations to evaluate and improve its program. Management is responsible for fostering a culture in which commercial objectives never displace legal obligations, ethical conduct, product integrity, or respect for independent clinical decision-making.

Every person acting for or on behalf of Total Surgical shares responsibility for the Compliance Mandate. By providing clear standards, practical tools, meaningful oversight, and a trusted process for raising concerns, Total Surgical seeks to earn and preserve the confidence of its customers, business partners, payors, the patients served by our customers, and the communities in which we operate.