Annual Declaration of Compliance with California Law
Varian Medical Systems has adopted an Anti-kickback / Anti-fraud Compliance Program relating to relationships with health care professionals entitled "Varian's Commitment to Legal and Ethical Interactions with Health Care Providers." This program addresses interactions with respect to our medical device products and services.
Varian believes that the medical device industry has unique differences from the drug and pharmaceutical industry. The medical device industry has established voluntary codes of ethics such as the National Electrical Manufacturers Association Code of Ethics on Interactions with Health Care Providers, ("NEMA Code") and the AdvaMed Code of Ethics on Interactions with Health Care Professionals ("AdvaMed Code"). Varian's compliance program is modeled on these industry-specific codes. Both of these Codes are substantially equivalent to the Pharmaceutical Research and Manufacturers of America Code on Interactions with Healthcare Professionals (PhRMA Code), but are focused specifically on our industry as opposed to the pharmaceutical industry.
Varian recognizes that any compliance program must be a dynamic program. As such, our program embraces the concept of continual improvement, and Varian will aggressively monitor and audit performance and make necessary changes on an ongoing and regular basis.
Varian has developed an Anti-kickback / Anti-fraud Compliance Program that we believe meets the compliance goals set forth by the State of California's Health & Safety Code §§ 119400 – 119402 (SB 1765). To our knowledge, we are, in all material respects, in compliance with our Anti-kickback / Anti-Fraud Compliance Program and applicable law.
This declaration is made only for the purpose of compliance with California Health and Safety Code section referenced above and should not be interpreted as a declaration of compliance with any other statute or regulation.
Signed,
Vy Tran – December 08, 2009
VP-Corporate Regulatory Affairs and AKAF Compliance Officer
Varian Medical Systems, Inc.
Varian will provide its Compliance Manual and declaration as it relates to the California Health & Safety Code 119400-119402 via fax or hardcopy upon request. The manual is descriptive of the overall program. To request this information please contact us at 1.800.367.4402 if you are in the U.S. or Canada; or 1.650.424.6876, if you are calling from any other location, worldwide.
