Supplier Code of Conduct

Purpose and Scope

This Supplier Code of Conduct establishes the mandatory ethical, legal and operational standards that all suppliers, distributors, logistics partners and service providers (“Suppliers”) must comply with when conducting business with MaxMed Systems.
Compliance with this Code is a contractual condition. MaxMed reserves the right to suspend or terminate cooperation with any Supplier that fails to meet these requirements.

This Code applies to all refurbished medical equipment, parts, accessories, logistics operations, documentation, servicing and any related commercial or technical activities.

Legal and Regulatory Compliance

Suppliers must fully comply with:

• all applicable EU laws and regulations
   
• national laws in the Supplier’s jurisdiction
   
• MDR requirements where applicable
   
• standards governing refurbished medical equipment
   
• international trade, export control and sanctions regulations
   
• tax, labor and occupational safety legislation
   

Non-compliance constitutes immediate grounds for contract termination.

Product Integrity and Technical Compliance

Suppliers must guarantee that:

• all refurbished systems originate from lawful sources
   
• equipment is free of liens, export restrictions or undisclosed third-party claims
   
• technical condition is accurately documented
   
• performance data, detector status and coil/scanner condition reports are authentic and complete
   
• no alterations are made to identifiers, labels, serial numbers or service logs
   
• all refurbishments are performed according to recognized EU standards
   

Any misrepresentation of technical condition is considered a material breach.

Transparency of Origin and Documentation

Suppliers must provide, upon request:

• documented proof of origin (hospital/clinic, country, de-installation reports)
   
• full configuration lists
   
• maintenance and service history where available
   
• software license status
   
• hours, usage metrics and cycle data where applicable
   

Failure to disclose accurate information constitutes non-compliance.

Anti-Corruption and Business Ethics

MaxMed enforces a strict zero-tolerance policy toward:

• bribery
   
• kickbacks
   
• facilitation payments
   
• conflicts of interest
   
• undisclosed commissions
   
• improper advantages or inducements
   

Suppliers must maintain books and records that accurately reflect all transactions.

Data Protection and Confidentiality

Suppliers must comply with GDPR and EU data-protection standards, ensuring:

• secure handling of business data
   
• confidentiality of customer information
   
• protection against unauthorized access or disclosure
   

All shared information is confidential and may not be reused or disclosed without MaxMed’s written consent.

Labor Standards and Human Rights

Suppliers must uphold internationally recognized labor standards, including:

• prohibition of forced labor, child labor and human trafficking
   
• safe and compliant working environments
   
• non-discriminatory hiring and employment practices
   
• fair compensation consistent with local law
   

Non-adherence results in immediate suspension.

Environmental Responsibility

Suppliers must:

• manage waste from de-installation and refurbishment responsibly
   
• comply with WEEE and environmental regulations
   
• avoid improper disposal of electronics and medical components
   
• implement recycling processes where applicable
   

Supply Chain Security and Logistics

Suppliers must ensure:

• secure handling of equipment during de-installation, packaging and transport
   
• packaging appropriate for long-distance and international shipment
   
• full transparency in carrier selection, insurance and export documentation
   
• compliance with Incoterms agreed in the contract
   

Inspection, Audits and Corrective Actions

MaxMed reserves the right to:

• request inspections of refurbished systems prior to shipment
   
• conduct audits of supplier facilities, records or procedures
   
• require corrective actions with defined timelines
   

Failure to complete corrective actions may lead to termination of cooperation.

Reporting Obligations

Suppliers must promptly disclose:

• any legal proceedings that may impact compliance
   
• any changes in ownership relevant to business integrity
   
• any incident affecting the safety, legality or technical status of equipment
   
• any breach of this Code
   

Non-reporting constitutes an independent breach.

Consequences of Non-Compliance

MaxMed may take one or more of the following actions:

• written warning
   
• suspension of purchase orders
   
• cancellation of open orders
   
• removal from the approved supplier list
   
• contract termination
   
• legal action for damages
   

MaxMed maintains full discretion over applicable remedies.

Acceptance of the Supplier Code of Conduct

By engaging in any commercial activity with MaxMed Systems, the Supplier:

• acknowledges receipt of this Code
   
• agrees to comply fully
   
• accepts that compliance forms part of every quotation, contract or purchase order
   

Contact for Compliance Matters

MaxMed Systems – Compliance Office
E-mail: legal@maxmedsystems.eu
Website: www.maxmedsystems.eu