1. Introduction
This Code of Ethics represents the set of ethical principles and behaviors that
Mediryze S.a.s. adopts in carrying out its activities. It constitutes a formal
commitment to employees, collaborators, business partners, customers, healthcare professionals, and
public and private stakeholders.
Mediryze recognizes ethics as the foundation of its growth strategy and adheres to the
values ​​promoted by MedTech Europe, Confindustria Dispositivi Medici, and applicable Italian and European legislation (e.g., MDR 2017/745, GDPR, Legislative Decree 231/2001).

2. General Principles
• Legality
All company activities are conducted in full compliance with applicable
national, EU, and international regulations.
• Transparency and integrity
Relationships with customers, suppliers, healthcare professionals, and institutions are based on
criteria of honesty, fairness, and transparency, avoiding any form of conflict of
interest.
• Confidentiality and data protection
Mediryze is committed to protecting confidential information and personal data
in accordance with the principles of the GDPR.
• Patient-centricity
All the company’s activities are aimed at improving the quality of healthcare
care, in compliance with the highest standards of safety and effectiveness.
• Social responsibility and sustainability
Mediryze acts responsibly towards the community, the environment, and the
healthcare system, promoting sustainable business models.

3. Relationships with healthcare professionals
• Relationships with doctors, nurses, and healthcare personnel are based on ethics,
professional independence, and scientific appropriateness.
• Any collaborations or consultancies are governed by transparent contracts, with
proportionate and documented compensation.

• Gifts, travel, or personal benefits that could even potentially influence clinical decisions are prohibited.

4. Interactions with healthcare facilities
• Mediryze is committed to maintaining transparent and fair relationships with public
hospitals, private clinics, accredited institutions, and purchasing centers.
• All procurement procedures are conducted in compliance with public procurement
regulations, flow traceability, and the principles of fair competition.

5. Promotional Activities and Training
• Device promotion activities are based on scientifically
sound, up-to-date, and documented content.
• The organization of events, courses, or training sessions always complies with
MedTech guidelines, including transparency of funding and approval of
content by the scientific management.
• Clinical Product Specialists operate without interfering with clinical decisions,
limiting themselves to providing technical and informational support.

6. Anti-Corruption and Reporting
• Mediryze has zero tolerance for any form of corruption, whether active
or passive, direct or indirect.
• Any suspicious, unlawful, or contrary to this Code behavior can be
reported confidentially to:
[email protected]
All reports will be treated confidentially and without repercussions for those who
make them in good faith.

7. Application and Updates
This Code is binding on all Mediryze employees, collaborators, and partners.
Any violations may result in disciplinary action or termination of contractual
relationships.

The Code is reviewed annually by Management and updated in accordance with
current regulations and industry best practices.

Attachments

• MedTech Europe Regulation

• Confindustria Medical Devices Code of Ethics

• Internal guidelines for events and sponsorships

Allegato 1 – Regolamento MedTech Europe

The MedTech Europe Regulation is the main European code of conduct for companies in the medical device sector. It establishes the ethical principles and good practices to be adopted in relationships between companies and healthcare professionals.

Main principles:

1. Integrity and Responsibility: Every interaction must be guided by ethical, educational, or scientific purposes.

2. Transparency: Companies must disclose transfers of value (monetary or in-kind) to healthcare workers.

3. Donations and sponsorships: can only be made to healthcare institutions, never to individual professionals.

4. Third-Party Events: Each sponsored event must be approved through the< 0 >EthicalMedTech Conference Vetting System.

5. Contracts and remuneration: each consultancy or training relationship must include a written, appropriate and documented contract.

6. Promotional material: must be evidence-based, up-to-date and internally approved.

Compliance with these standards ensures the legitimacy of commercial activities, protects the company’s reputation, and strengthens trust in the healthcare sector.

Annex 2 – Confindustria Medical Devices Code of Ethics

The Confindustria Medical Devices Code of Ethics is a national reference that establishes the rules of conduct for member companies, inspired by the values ​​of transparency, integrity and social responsibility.

Main contents:

1. General principles: respect for the law, free competition and human rights.

2. Relationships with healthcare professionals:

– Obligation of independence in clinical decisions.

– Prohibition of providing undocumented or irrelevant benefits.

– Contractual transparency and proportionate compensation.

3. Sponsorships:

– Only CME events or events with documented scientific purposes.

– Internal approval and expense traceability.

4. Whistleblowing procedures:

– Internal system for the confidential reporting of unethical behavior.

5. Continuous training:

– Promotion of the cultural and professional growth of employees and collaborators in compliance with company policies.

Adherence to the Code is a condition for remaining in Confindustria Apparecchi Medicali and represents a binding commitment.

Annex 3 – Internal Guidelines for Mediryze Events and Sponsorships

Mediryze is committed to ensuring that every event, sponsorship or promotional activity< 0 >is conducted in compliance with industry codes of ethics.

Criteria and policies:

1. Types of events:

– National and international scientific conferences

– Technical workshops on innovative devices

– ECM training courses

2. How to participate:

– Sponsorship of the event through a contract with the organizing body

– Reimbursement of expenses (travel, accommodation) only if justified and documented

– No personal benefits for individual participants

3. Approval and traceability:

– Each initiative is approved by the Management and administratively tracked

– Invitations are reserved for professional profiles consistent with the themes of the event

4. Material and contents:

– All training material must be scientifically validated

– Speakers must declare any conflicts of interest

5. External communication:

– Mediryze does not use events for direct advertising purposes, but only as a training channel and for technical updates

These guidelines ensure compliance with MedTech Europe, transparency in relationships with healthcare professionals and consistency with the company mission.