Governance

Committee Composition

Below is a summary of our committee structure and membership information. To read more about any of the committees, click on committee names in the chart below.

Chairperson

Member

Financial Expert

Audit Committee Compensation Committee Nominating and Governance Committee Jack R. Blair      Peter  C.  Farrell       Lesley H. Howe   Robert  J. Hunt     Eileen M. More      Peter Leddy, Ph.D      Richard W. Treharne

Highlights

Committee Charters

	Audit Committee
	Compensation Committee
	Nominating and Governance Committee
	Lead Independent Director

Governance Documents

	California Transparency Law Declaration
	Code of Ethical Business Conduct (including Code of Ethics for Senior Financial Officers)
	Corporate Governance Guidelines
	Insider Trading Policy
	MDMA Revised Code of Conduct
	NuVasive® Global Business Ethics and Compliance Program
	NuVasive Incentive Compensation Recoupment Policy

NuVasive Business Ethics Program

Commitment to Business Ethics and Compliance

NuVasive, is committed to conduct all of its business activities in accordance with the highest standards of ethics, professionalism, integrity, responsibility and accountability. No commercial objective is more important that conducting our business ethically and in full compliance with all applicable federal, state and local laws, especially those designed to prevent fraud and abuse. In order to ensure such compliance, NuVasive has adopted a comprehensive compliance program, entitled NuVasive's Global Business Ethics and Compliance Program ("Program"), which is designed to prevent and detect unethical business conduct, violations of law or company policy.

It is NuVasive's policy that all of its officers, directors, employees, agents and independent contractors comply with the Program and the policies and procedures created to support the Program. In the event NuVasive becomes aware of a violation of law or company policy, it will investigate the matter and, where appropriate, take disciplinary action and implement any necessary corrective measures to prevent reoccurrence.

The Program is designed to adhere to the requirements as set forth in the U.S. Federal Sentencing Guidelines and recommendations contained in the OIG's compliance program guidance. The Program is dynamic and is regularly reviewed and enhanced it to meet the company's evolving business ethics and compliance needs. The following is an overview of the elements of the Program.

• Written Standards. NuVasive has adopted written standards regarding compliance, including a Code of Ethical Business Conduct (required reading for each employee), a notice regarding our Commitment to Compliance (posted at each location) and appropriate policies and procedures.
• Leadership & Structure. NuVasive has appointed a Compliance Officer and established two tiers of Compliance Committees consisting of upper and middle management from various departments to implement and monitor its Program.
• Education and Training. NuVasive has developed a training program tailored to each employee's individual responsibilities, including training regarding compliance with our Program, Code and specific laws and regulations such as the Food Drug & Cosmetic Act, Medicare fraud and abuse laws (e.g., Anti-Kickback Statute; False Claims Act), Foreign Corrupt Practices Act and other applicable federal, state and local laws, rules and regulations.
• Internal Lines of Communication. NuVasive has established a confidential disclosure program (the "Integrity Hotline") that permits employees to anonymously disclose ethical, legal and compliance concerns through a toll-free telephone number that cannot be traced.
• Audit & Monitoring. NuVasive conducts routine and random audits to ensure compliance with all legal and regulatory requirements.
• Enforcement & Discipline. NuVasive has created written disciplinary guidelines to address any issues of non-compliance and such guidelines have been communicated to all employees and are consistently enforced.
• Corrective Action Procedures. NuVasive investigates any and all ethical, legal and compliance issues raised and takes appropriate action to resolve any such matters and prevent reoccurrence.

To see a copy of the NuVasive Global Business Ethics and Compliance Program, please click here.
To see a copy of the NuVasive California Comprehensive Program Overview, please click here.
To see a copy of the NuVasive California Declaration to its Program, please click here.
To see a copy of the NuVasive Code of Ethical Business Conduct, please click here.

For questions or comments regarding our compliance program, please call, toll free, the NuVasive Integrity Hotline at 1-866-907-7409 or e-mail us at ComplianceOfficer@NuVasive.com.