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Conflict of Interest Policy 

Pathway Medical is committed to the highest levels of integrity. Employees of the company are expected to conduct their relationships with each other, the company, and outside organizations with objectivity and honesty. Employees are obligated to avoid and disclose ethical, legal, financial, or other conflicts of interest involving the company, and remove themselves from a position of decision-making authority with respect to any conflict situation involving the company.  

Pathway Medical does not accept funds from the medical device, pharmaceutical, or biotechnology industry, under any circumstance. Pathway Medical employees may not work or consult for, own stock in, or receive payment or gifts from the medical device, pharmaceutical, or biotechnology industry. Neither Pathway Medical nor its employees may accept speaking fees, travel funds for any purpose, entertainment, or other considerations that could possibly be construed as influencing or compromising the judgment of the employee or the integrity of the content provided in our services.  

A medical device, pharmaceutical, or biotechnology company is, for this purpose, defined as a manufacturing and/or marketing entity that derives more than 20% of its gross annual revenues from the development, manufacture, or sale of medical device, pharmaceutical, or biotechnology products. Ownership of mutual funds, blind trusts, and similar investments in which the investor is insulated from participating in the fund's investment decisions are excluded from the above mentioned prohibitions.  

All Pathway Medical employees must complete a conflict of interest disclosure questionnaire on a yearly basis. Employees shall also disclose whether their spouse and/or dependent is an officer, member, owner, shareholder, employee, or agent of a company in the medical device, pharmaceutical, or biotechnology industry. Any such disclosures shall be examined by Pathway Medical's Conflict-of-Interest Committee.  

The federal income tax return of each company officer shall be submitted to the Vice President for Finance for review at the time of submission each year for the purpose of confirming that each employee has conformed to Pathway Medical's conflict-of-interest policy.