Vapotherm, Inc. is committed to promoting ethical practices throughout the organization. Through the Board of Directors, the Company sets high standards for our employees, officers and directors. It is the duty of the Board of Directors to serve as a fiduciary for shareholders and to oversee the management of the Company’s business. To fulfill its responsibilities and to discharge its duty, the Board of Directors follows procedures and standards, including those that are set forth in these guidelines. The Company’s policies and practices, through Board review and supervision, are continually reviewed and enhanced as appropriate or as required by applicable laws and regulations.

On October 20, 2021, the Board of Directors of Vapotherm, Inc. (the “Company”) adopted the following new Code of Business Conduct (the “Revised Code”), which will become effective on January 1, 2022. The Revised Code applies to all employees, officers and directors of the Company and its subsidiaries. The Revised Code was updated to ensure that all policies and procedures included in the Revised Code are reflective of the actual current practices of the Company and meet any minimum requirements set forth by applicable law and/or generally aligned with the industry standards. The adoption of the Revised Code did not relate to or result in any waiver, explicit or implicit, of any provision of the current Code of Conduct.

Professional Conduct Principles

At Vapotherm we believe in the value of establishing bedrock principles that are universally applicable. We also understand that guidance is most impactful when people feel as though they have ownership in its creation. To that end, Vapotherm employees came together to create our Professional Conduct Principles to guide employees in decision-making in the workplace.

  1. We are accountable to ourselves and to others for acting with integrity, respect, and empathy.
  2. We seek continuous improvement by operating transparently and embracing open discussion.
  3. We are engaged global citizens who value diversity, inclusion, and social responsibility.

Hotline

Vapotherm is committed to maintaining a culture that promotes prevention, detection, and resolution of conduct that does not conform with the law or Vapotherm’s Professional Conduct Policies, including violations of our Conflict Mineral Policy. Anonymous reporting via our Professional Conduct hotline is available 24 hours, 7 days a week by phone at 1-844-308-2530, submitting a claim on www.intouchwebsite.com/VapothermProfessionalConduct, or email at VapothermProfessionalConduct@getintouch.com.

Compliance Program

Vapotherm is dedicated to maintaining an effective company-wide compliance program consistent with the Advamed Code of Ethics as well as the relevant guidance set forth by both the Office of Inspector General, U.S. Department of Health and Human Services and the U.S. Sentencing Commission.

Code of Business Conduct and Ethics

Vapotherm, Inc is committed to ensuring that its business practices are conducted in an ethical and transparent manner and in compliance with all applicable laws, including the California Health and Safety Code §119400-119402 (the “California Code”).

Vapotherm, Inc has developed a Comprehensive Compliance Program, consistent with HHS-OIG guidance and in accordance with the AdvaMed Code of Ethics on Interactions with Health Care Professionals, a voluntary ethical code specifically tailored for the unique interactions between the medical technology industry and our health care professional partners. This program is reasonably designed to prevent and detect violations and meet the goals set forth by the State of California.

Annual Spending Limit

Vapotherm, Inc has established an annual aggregate dollar limit for promotional materials or items or activities that the company may give or otherwise provide to an individual HCP in accordance with AdvaMed Code standard and relevant guidance.

Compliance Declaration

As of June 1, 2022, to the best of its knowledge and based on a good faith understanding of the requirements of the California Code, Vapotherm, Inc declares that it is in compliance with its Comprehensive Compliance Program and the California Code.

For a copy of our compliance program please call +1(603)-658-0011.

Last update: June 27, 20