Anti-Kickback/Anti-Fraud Compliance

Annual Declaration of Compliance with California Law

Varian Medical Systems, Inc. (Varian) has adopted a Comprehensive Ethical Compliance Programme relating to relationships with healthcare professionals. This programme 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 Healthcare Providers, (“NEMA Code”) and the AdvaMed Code of Ethics on Interactions with Healthcare Professionals (“AdvaMed Code”). Varian’s compliance programme is modelled 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 recognises that any compliance programme must be a dynamic programme. As such, our programme 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 a compliance programme that 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 compliance programme and applicable law.

This declaration is made only for the purpose of compliance with the 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 – 30 June 2021
SVP, Chief Compliance Officer
Varian Medical Systems, Inc.

Varian will provide its Comprehensive Compliance Programme and declaration as it relates to the California Health & Safety Code 119400-119402 via fax or hardcopy upon request. To request this information please contact us at +1.650.424.8120, if you are calling from any other location, worldwide.