This glossary is provided to help website users understand some of the words and phrases that are used and to help ensure that these words and phrases are used consistently.

Terms	Definition
AdvaMed	The medical device industry trade association. Information regarding AdvaMed is available at www.advamed.org
Anti-Kickback Laws	Federal and state laws that make it illegal to offer or provide anything of value in order to induce someone to order, purchase or recommend any goods or services that are paid for in part or whole by a federal health care program such as Medicare or Medicaid. The federal law is codified at 42 U.S.C. Section 1320a-7b(b).
Approved Medtronic Customer Meeting Facility	One of the approved locations for Customer meetings and lodging that are listed on the Medtronic Compliance website
BCS Policy	A policy adopted by MSD that is related to one or more of the Business Conduct Standards.
Business Conduct Standards (BCS)	Medtronic's U.S. Business Conduct Standards, unless indicated otherwise by the related content.
Charitable Contributions	Contributions of services, money and/or products that are made pursuant to Business Conduct Standard #3.
Charitable Contributions Manager	The person designated by MSD's Vice President and Senior Legal Counsel to provide administrative support and services for MSD's charitable contributions activities. The name of the person is provided at Compliance Office Contacts.
Charitable Contribution Policies	The policies adopted by MSD to comply with Business Conduct Standard #3.
Charitable Contribution Program	MSD's policies, forms, templates and practices that establish the processes and procedures it uses to receive, evaluate, and implement charitable contributions.
Charitable Contribution Request Form	Standard forms used to identify all of the information and documents necessary for a MSD Contributions Committee to determine whether a contribution request satisfies the Charitable Contribution Policies and should be granted.
Co-Marketing Activity	A promotional event (e.g., referral dinner or meeting) or activity (e.g., brochure) that promotes a Customer's practice and MSD Products.
Code of Conduct	Medtronic Code of Conduct that establishes Medtronic's worldwide ethics and business standards. Additional information regarding the Code of Conduct is available at Medtronic Code of Conduct.
Community-Based Charitable Contributions	A charitable contribution provided to support community activities and charitable organizations that are not affiliated with a Customer.
Compliance Office	The MSD staff responsible for implementing policies, processes, system, and controls promoting compliance with applicable laws, policies, and contractual obligations, including Medtronic's U.S. Business Conduct Standards.
Corporate Charitable Contributions Committee	The committee that reviews and decides on requests for: (1) Community-Based Charitable Contributions for the Memphis metropolitan area; and (2) all Customer-Based Charitable Contributions requests, except for contributions regarding fellowships.
Customer	Defined in the U.S. Business Conduct Standards, but summarized here as anyone person or entity who is: (1) in a position to purchase, lease, recommend, use or arrange for the purchase or lease of MSD's products, or (2) affiliated with a Customer. Additional clarification regarding MSD's Customers are provided in the General Provisions: Identifying MSD Customers Policy.
Customer-Based Charitable Contributions	A charitable contribution provided: (1) at the request of a Customer; (2) to or for the benefit of a Customer; (3) to a charitable mission supported or sponsored by a Customer; or (4) to a charitable organization a Customer is affiliated with, e.g., on the board of directors or a professional association for Customers.
Customer Interaction	Defined in Business Conduct Standard #1 as a transfer of anything of value from Medtronic to a Customer.
Distributor	A person or organization under contract with MSD to promote and sell MSD's products to Customers.
Education Grant	MSD's financial support for a Third Party Meeting , not including a Scholarship.
Fellowship	An in-depth course of study and instruction with significant educational value at an academic medical institution for a specific period of time. Provides the fellow with an intellectual environment for acquiring the knowledge, skills, clinical judgment, and attitudes essential to the practice of the applicable sub-specialty.
Fellowship Charitable Contributions Committee	The committee that reviews and decides on Customer-Based Charitable Contribution requests to sponsor fellowships.
Fellowship Summary Questionnaire	A questionnaire approved by MSD's Vice President and Senior Legal Counsel that is required for all fellowship-related charitable contributions.
Independent Sales Representative	A person under contract with MSD or employed or under contract with a Distributor to promote and sell MSD's products to Customers.
Medicare	A health care program administered by the federal government that pays for certain health care services for Medicare beneficiaries, the majority of whom are eligible as a result of their age or because of a long-term disability.
Medicaid	A health care program primarily administered by state governments, but funded in part by the federal government, that pays for certain health care services for Medicaid beneficiaries, who are eligible as a result of financial status.
MSD	Medtronic Sofamor Danek
MSD Compliance Officer	The person designated by MSD to be primarily responsible for developing and maintaining MSD's BCS Compliance Program.
MSD Compliance Website	One or more websites maintained by MSD that provide information regarding the BCS and compliance with the BCS.
MSD Contribution Committees	The Corporate Charitable Contributions Committee; MSD Local Community Charitable Contributions Committees; Fellowship Charitable Contributions Committee.
MSD Local Community Charitable Contributions Committee	The committees designated by local leaders at each community in which MSD maintains a facility with employees, other than Memphis, to review and decide on Community-Based Charitable Contributions for their local community.
MSD Representative	A MSD employee, Distributor, Independent Sales Representative, or other agent, not including Business Colleagues.
MSD Training and Education Program	A training and education program regarding MSD Products provided by MSD to Customers in compliance with BCS #7.
Product Division	As of the effective date of this glossary, MSD's product divisions are: Biologics Interbody Cervical Thoracolumbar
Product Division Contributions Designee	The individual(s) designated for each MSD product division to review and evaluate requests for product charitable contributions, typically related to a charitable mission to provide health care services to indigent patients in and outside of the United States.
Sales Personnel	Anyone employed as a part of MSD's sales department, including employed sales representatives, Distributors, Independent Sales Representatives, sales managers or directors.
Senior Contribution Approver	The person or person(s) who are required to evaluate and approve charitable contributions that exceed certain dollar thresholds as defined in BCS #3 and the Customer-Based Charitable Contributions Policy.
Senior Manager, Accounts Payable	Currently Lori Brunson (lori.brunson@medtronic.com)
Scholarships	MSD's financial support for health care professionals-in-training (residents, fellows, etc.) to attend a Third Party Meeting.
Tax Exempt Charitable Organization	An organization that qualifies for tax-exemption under Section 501©(3) of the Internal Revenue Code or an organization that qualifies for tax-exemption under Section 501©(6) of the Internal Revenue Code and engages in scientific, educational, or other charitable activities.
Third Party Meeting (TPM)	The educational and/or scientific conferences, congresses, meetings, and other forums for health care professionals described in BCS #8 that are sponsored by a person or organization other than MSD.
Third Party Meeting Administrator	The person designated by MSD's Vice President and Senior Legal Counsel to provide administrative support and services for MSD's Third Party Meeting financial support. The Third Party Meeting Administrator's name and contact information is available on the Third Party Meeting page.
U.S. Business Conduct Standards (BCS)	Detailed local requirements and limitations on Customer relationships for Customers located in the United States. There are different Business Conduct Standards for the different countries in which Medtronic does business. The applicable Business Conduct Standards are determined by the Customer's home country.