Anti-Bribery and Anti-Corruption

The cornerstone of our program is Zimmer Biomet’s commitment to ensuring that team members and business partners conduct themselves ethically and in compliance with all applicable laws, regulations, industry codes, and company policies, including refraining from any bribery, kickback or corruption-related activities. 

Zimmer Biomet has established anti-bribery and anti-corruption policies and procedures that cover, among other things, interactions with healthcare providers and government officials. These policies and procedures are reinforced by a robust training program as well as periodic auditing and monitoring. Zimmer Biomet has a zero-tolerance policy when it comes to bribery and corruption.

Code of Business Conduct and Ethics

The Zimmer Biomet Code of Business Conduct and Ethics embodies our commitment to the highest ethical standards and compliance with all applicable laws and regulations. It reinforces our commitment to acting ethically and with integrity in all that we do and guides positive interactions with customers and with people in the communities in which we live and work.

The Code of Business Conduct and Ethics is available in English as well as 30 additional languages:

Industry Code Compliance

Zimmer Biomet is committed to compliance with a variety of industry codes designed to ensure that relationships with healthcare professionals and other customers are conducted in accordance with the highest ethical standards and transparency. These codes each recognize that adherence to ethical standards and compliance with applicable laws is critical to the industry’s ability to preserve and promote its collaboration with healthcare professionals and serve to clarify and distinguish between appropriate and inappropriate activity between healthcare professionals and companies.

Without reservation, Zimmer Biomet strongly endorses both the spirit and the letter of the relevant industry codes for associations of which Zimmer Biomet is a member, including the following:

Global Third Party Partners

We depend on third parties to conduct business on our behalf all over the world, and we have a due diligence screening process in place to ensure our third parties share our commitment to the highest ethical standards and operate in accordance with all applicable laws, regulations, and industry codes. Third parties who are required to complete Zimmer Biomet’s due diligence process can review the requirements and expectations that must be followed in the relevant resources on the Global Third Party Partners page.

Speak Up: Report a Compliance Concern

Being a Trusted Partner is fundamental to the success of Zimmer Biomet and our ability to deliver on the mission to improve the lives of patients around the world. 

One way to gain trust is by empowering every voice to speak up when something is wrong. Zimmer Biomet has an online reporting system and global direct-dial telephone numbers for the reporting of compliance concerns (the “Speak Up Hotline”). Anyone may use the Speak Up Hotline to ask questions or report known or suspected compliance concerns related to violations in any of the following areas:

  •  Applicable laws, regulations, and/or industry codes
  •  U.S. federal health care program requirements
  •  Zimmer Biomet’s Code of Business Conduct and Ethics
  •  Zimmer Biomet’s policies and procedures

Concerns may also be reported about Zimmer Biomet’s accounting, internal controls or auditing-related matters; or for any other general compliance concerns or issues.

Any form of retaliation against anyone who raises a concern in good faith is prohibited. 

The Speak Up Hotline is available 24 hours a day, seven days a week. All reports are received by a trained operator at an independent third party provider hired by Zimmer Biomet. Reports are confidential and may be made anonymously, if permitted by law. Zimmer Biomet will investigate and follow up on all Speak Up Hotline reports received. 

Online  zimmerbiomet.com/speakup

Our Global Compliance Team

Zimmer Biomet’s global Compliance team is comprised of highly skilled and dedicated lawyers and compliance professionals, located in countries around the world, including the United States, Mexico, Brazil, Switzerland, Spain, the Netherlands, United Kingdom, Singapore, Japan, and China.

There are three regional compliance teams supporting the business in the Americas; Asia Pacific (APAC); and Europe, Middle East & Africa (EMEA), as well as global compliance teams responsible for compliance operations, investigations, monitoring, third party due diligence and trade compliance.  Collectively, the teams work to ensure Zimmer Biomet team members have the training, tools, and guidance necessary to perform their jobs in a legal, ethical, and compliant manner.

 

Global Compliance Officers

Copy of Angela Main_Website - 1
Angela Main
Senior Vice President, Global Chief Compliance Officer

Angela leads Zimmer Biomet’s global Compliance function as well as the regional Legal function in Asia Pacific. She is responsible for the broad spectrum of legal and compliance advice and solutions to both the Zimmer Biomet organization as a whole and to the Asia Pacific business entities, including the implementation of compliance policies and training to team members and business partners as well as the screening of business partners.

Prior to joining Zimmer Biomet in 2010, Angela worked for Covidien in Singapore, Lloyds TSB Bank plc in London, and Texas Instruments in its European and Asia Pacific regional offices. She has extensive international legal and compliance experience in the healthcare, financial services and technology sectors.

Copy of Grey Background for PPT (500x500px) - Joe Urban
Mathias Gubler
Senior Director, Compliance Officer, EMEA

Mathias leads the Europe, Middle East and Africa Compliance team, where he provides oversight for all compliance matters and compliance initiatives in the region, in addition to his role as Compliance Senior Director for the Recon DTS businesses. Previously, he led the Global Compliance Operations team, responsible for the strategic oversight of all global compliance training initiatives as well as the development and maintenance of all global compliance policies and procedures. He joined Zimmer Biomet in February 2013, providing compliance support to the EMEA Central and Africa regions. Before ZB, Mathias gained broad international work experience in the field of legal and compliance, where he served as a Junior Legal Counsel for the Legal & Compliance Department of ABB Switzerland, and through his work at law firms in Switzerland, Singapore and at the District Court of Bulach-Zurich, Switzerland. He was admitted to the bar by the Supreme Court of Zurich and holds degrees from the University of Augsburg, Germany, and University of Zurich, Switzerland.

Benjamin Kwak
Benjamin Kwak
Vice President, Compliance Officer, Americas and Deputy Chief Compliance Officer

Benjamin is responsible for the global Compliance functions, which include the compliance monitoring, investigations, operations and third-party compliance teams. He also oversees efforts to drive continuous improvements to the Compliance program.

Benji joined ZB in February 2014. Previously, he was in private practice, focused on white collar criminal defense, government investigations, and corporate compliance matters. Benji received his Bachelor of Arts degree from Princeton University and his J.D. from Columbia Law School.

Global Compliance Leaders

Copy of Copy of Grey Background for PPT (500x500px) (540 x 560 px) - Phaedon
Phaedon Asderis
Director, Global Compliance Operations

Phaedon is the Director of Global Compliance Operations at Zimmer Biomet, a role he assumed in July 2024. In this position, Phaedon oversees the strategic direction of global compliance training initiatives, the development and maintenance of compliance policies and procedures, compliance communications, and compliance program governance. Since joining Zimmer Biomet in 2016, he has held various roles within the Global Compliance Audit team and was part of the EMEA Regional Compliance function, focusing on Emerging Markets. Prior to Zimmer Biomet, Phaedon worked at an external audit firm in Frankfurt, Germany for five years, conducting financial audits, forensic investigations, and financial due diligence reviews. He earned his Master of Business Administration (Diplom-Kaufmann) from the University of Greifswald, Germany, with a focus on Auditing, Taxation, and Psychology.

Chelsea Keeton Headshot
Chelsea Keeton
Senior Director, Global Compliance Investigations

Chelsea is Senior Director and Lead Counsel for the Global Compliance Investigations function at Zimmer Biomet. In this role, she leads the team responsible for Zimmer Biomet's Speak Up hotline and compliance investigations across the globe and works closely with stakeholders on continuous improvement. Chelsea first joined Zimmer Biomet in 2021 as the Director of Compliance Investigations for the EMEA region before becoming Director and Senior Counsel for Investigations in the Americas.

Prior to joining Zimmer Biomet, Chelsea advised organizations navigating monitorships, Deferred Prosecution Agreements (DPAs), and complex investigations before the U.S. and European authorities. She served as Compliance Counsel at VEON during its DPA and monitorship with the United States Department of Justice and began her legal career at Baker McKenzie. She is currently based in Houston, Texas.

Alina Mulet (540 x 560 px) - Joe Urban
Alina Mulet
Acting Head, Global Trade Compliance
Copy of Copy of Grey Background for PPT (500x500px) (540 x 560 px) - Roberta Rima
Roberta Rima
Vice President, Global Compliance Monitoring, Audit & Analytics

Roberta joined Zimmer Biomet in December 2023. In her role, she leads the Global Compliance Monitoring, Audit & Analytics team, where she is responsible for overseeing the execution of the annual compliance monitoring and audit plan, as well as the compliance data analytics program, with a focus on improving detection and deterrence of misconduct and addressing key high-risk areas. Before Zimmer Biomet, Roberta was Head of Third Party and Corporate Compliance Audit for Gilead Sciences. She has previously worked for Genetech, Nestle Skin Health, S.A. and PwC in internal audit, forensic accounting, and compliance roles. Roberta is a graduate of Bocconi University in Milan, Italy and is a Certified Fraud Examiner.

Copy of Copy of Grey Background for PPT (500x500px) (540 x 560 px) - Valeria
Valeria Souza Cruz
Director, Global Third Party Compliance

Valeria Souza Cruz is Director, Global Third Party Compliance at Zimmer Biomet, a role she assumed in December 2024. In this role, she leads a global team responsible for third party risk management and the due diligence process for Zimmer Biomet’s third party distributors and vendors. Before Zimmer Biomet, Valeria worked at PwC in the Global Intelligence and Strategic Threat Management practice. She is a Latin America specialist and has focused most of her career on anticorruption, government affairs, and business development. Valeria previously worked at Clarabridge, the Council of the Americas, the World Bank, the Organization of American States, IBM Brasil, and Petrobrás. Originally from Rio de Janeiro, Brazil, she earned an M.A. in Latin American studies from Georgetown University, focusing on Public Policy, and a B.A. in Economics from the Pontifícia Universidade Católica of Rio de Janeiro.