CODE OF CONDUCTDO THE RIGHT THING

DJO Global requires all of its Directors,

Officers and Employees to observe

high standards of integrity and honesty, and

to act with care, diligence and fairness in

all business activities. Interactions with all

stakeholders and wider society should be

conducted in an ethical and legal manner.

To that end, all of us must comply with this

Code and all supporting policies, the laws

and regulations of all countries in which we

operate, and with all applicable national and

international codes.

VISION

At DJO Global, our aim is to enable people to

regain the joy and comfort of natural motion.

MISSION

From prevention to recovery, DJO Global

enables people to live their lives to the fullest

by providing intelligent medical devices and

services. We value an open dialogue with our

customers to gather insights that guide our

innovations and continuous improvement.

WEBSITE

www.djoglobal.com

Table of Contents

• Who Must Comply. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

• Questions and Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

• Policy Statement & Compliance . . . . . . . . . . . . . . . . . . . . . . . 4

• Equal Opportunity / Nondiscrimination . . . . . . . . . . . . . . . . . . 5

• Harassment & Drug-Free Work Environment . . . . . . . . . . . . . . 6

• Confidential Information . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

• Protected Health Information . . . . . . . . . . . . . . . . . . . . . . . . 8

• Obligations For Senior Officers . . . . . . . . . . . . . . . . . . . . . . . 9

• Insider Trading . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

• Accurate Recording & Reporting . . . . . . . . . . . . . . . . . . . . . . 11

• Fraud & Abuse . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

• Manufacturing & Promotion . . . . . . . . . . . . . . . . . . . . . . . . 13

• Fair Dealing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

• Dealing With Competitors . . . . . . . . . . . . . . . . . . . . . . . . . 15

• Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

• Dealing With Suppliers . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

• Dealing With Governments . . . . . . . . . . . . . . . . . . . . . . . . 18

• Contributions & Improper Payments . . . . . . . . . . . . . . . . . . . 19

• Protection & Proper Use of DJO Property and Assets . . . . . . . . . 21

• Document Retention . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

• Safety, The Environment, and Sustainability . . . . . . . . . . . . . . 24

• Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

• DJO Global Compliance Hotlines . . . . . . . . . . . . . . . . . . . . . 27

What we do affects the reputation and success of DJO Global.

DO THE RIGHT THING

2

WHO MUST COMPLY WITH THIS CODE?

If you have received a copy of this Code, it means it applies to you! You are expected to read it and comply.

WHAT ARE YOUR OBLIGATIONS?

Because this Code and our supporting policies cannot cover every situation that may arise, you are expected to exercise good judgment and common sense in deciding the right actions to take.

You should ask questions if you are unclear about any aspect of this Code, or if you are not sure how to respond to an issue that the Code does not address.

If you are a member of the DJO management team (i.e., this includes supervisors, managers, directors, vice presidents, and executives), you are responsible for helping your teams understand the requirements of this Code, the DJO policies that support the Code, and how they should best be put into practice.

You are also responsible for providing assurance of compliance to the DJO Executive Team and Board of Directors. You must promptly report any known, suspected or observed violations of this Code or supporting policies of which you become aware.

WHAT ARE THE CONSEQUENCES?

DJO takes all alleged violation of the Code seriously and expects employees to be truthful and cooperate fully with any investigation. Each allegation is reviewed and, if substantiated, resolved through appropriate corrective and/or disciplinary action, up to and including termination of employment, or termination of a contract or business relationship with DJO business partners, depending on the circumstances.

Who Must Comply

This Code applies to all full and part-time DJO Global officers, directors, employees, and temporary staff worldwide. It also applies to all DJO business partners, including our independent sales force, except those parts of the Code specifically applicable only to employees.

QUICK REFERENCE

• You are responsible

for understanding the

requirements of this Code, the

DJO policies that support the

Code, and how they should be

put into practice.

• DJO is committed to working

only with individuals and

entities with a commitment

to ethical behavior that is

consistent with the standards

and guiding principles set

forth in this Code.

• You must promptly report any

known, suspected or observed

violations of this Code.

3

HOW TO ASK A QUESTION OR RAISE A CONCERN

You may at some time come across a situation that concerns you or appears to violate a DJO policy. We encourage you to report any such concerns promptly.

In general, you should first seek to address your concerns with your manager. If for some reason you believe this is not possible or appropriate, you may contact your Human Resources representative or the Corporate Compliance or Legal Department.

In all instances, all inquiries and discussions will be kept confidential to the extent reasonably possible and communicated on a need-to-know basis only.

These procedures can also be followed if you have a question, or are seeking clarification about any aspect of this Code and its supporting policies.

DJO’s hotline is managed by an independent company that provides an alternative means of reporting concerns 24 hours a day, 7 days a week. In the U.S., the hotline allows for anonymous reporting.

This service is not intended as a substitute for speaking directly with your immediate manager or supervisor or another leader at DJO. It is, however, another option available to you in the event you are uncomfortable with the other reporting options.

Although you are encouraged to identify yourself, you may remain anonymous when calling the Compliance Hotline. Local laws may limit the use of anonymous reporting to specific types of matters, and DJO processes incorporate such limitations. Please see page (27) for a listing of numbers.

Questions and Concerns

Anyone who raises a concern about a possible compliance breach in good faith will be supported by management and will not be subject to retaliation. Any act or threat of retaliation will be in itself considered a serious violation of this Code.

QUICK REFERENCE

• DJO maintains

toll-free compliance hotline

numbers for the U.S. and its

international locations. Please

refer to page (27) for a listing

of those numbers.

4

POLICY STATEMENT The successful business operation and reputation of DJO Global and its subsidiaries (collectively, “DJO” or the “Company”) is built upon the principles of fair business practices and ethical conduct of its employees.

Such practices and conduct extends, but is not limited to:

A. Accurate reporting, maintenance and confidentiality of all business and patient records;

B. Respect and care for the Company, including the Company’s name, property and ideas;

C. Avoidance of conflict of interest situations, or outside influences which could interfere with an employee’s ability to represent the Company appropriately or perform his or her job responsibilities fully;

D. Protection of confidential or proprietary information, which must be safeguarded from unauthorized or inappropriate disclosure outside the organization;

E. Rejection of tips, gifts, or entertainment, by employees and their families from a supplier, customer or governmental official, with the exception of small gifts of nominal value;

F. Relationships and dealings with customers and suppliers that are conducted on a fair and equitable basis; and

G. Dealings with competitors must comply with antitrust rules related to pricing and business tactics.

Policy Statement & Compliance

Employees must comply with all applicable laws, rules and regulations in performing duties for the Company.

COMPLIANCE WITH LAWS & REGULATIONS

The Company is committed to full compliance with the laws and regulations of the cities, states and countries in which it operates.

Numerous local laws and regulations define and establish obligations with which the Company, its employees and agents must comply. Under certain circumstances, local country law may establish requirements that differ from this Code. If you encounter a conflict between the applicable laws of two or more countries, consult with the DJO Legal Department to determine the best course of action.

5

EQUAL OPPORTUNITY EMPLOYMENT & NONDISCRIMINATION

It is DJO’s policy to provide a work environment that meets the highest standards of equal opportunity employment. Employees, customers, patients or suppliers will not be discriminated against because of age, disability, gender, military status, national origin, pregnancy, race, religion, sexual orientation or any other factor not related to DJO legitimate business interest.

Equal Opportunity / Nondiscrimination

QUICK REFERENCE

• DJO employees are

expected to promote a

work environment that

encourages diversity and

supports the ongoing

development of individuals’

skills and abilities.

• DJO employees are

expected to treat one

another with integrity,

honesty, courtesy, respect

and dignity.

6

HARASSMENT & DRUG-FREE WORK ENVIRONMENT

DJO is committed to providing a work environment free from discrimination and unlawful harassment. Actions, words, jokes or comments that are derogatory and based on an individual’s sex, race, ethnicity, age, religion, sexual orientation, or any other legally protected characteristic will not be tolerated.

Special attention should be paid to the prohibition of sexual harassment. Although sexual harassment appears in various forms and degrees, it generally consists of unwelcome sexual advances, unwelcome requests for

sexual favors or other unwelcome verbal or physical conduct of a sexual nature.

If you think you have been subjected to harassment at DJO, you must report it to any DJO supervisor or manager with whom you are comfortable speaking about the matter, or through one of the other reporting alternatives outlined in this Code of Conduct. Complaints of unlawful harassment are serious matters. DJO expects employees to report such behavior and for supervisors and managers to promptly act upon such allegations.

DJO is also committed to maintaining a business environment that is free from the effects of drug

and alcohol abuse. Employees are prohibited from the use, sale, dispensing, distribution, possession, or manufacture of illegal drugs, controlled substances, narcotics, or alcoholic beverages while working, except for the limited consumption of alcoholic beverages at company activities, functions or business situations in which consumption of alcoholic beverages is permitted.

Except as medically prescribed, employees are likewise prohibited from using or being under the influence of any prescription drug while working.

Harassment & Drug-free Work Environment

All employees are expected to conduct themselves in a business-like manner and with respect for others.

QUICK REFERENCE

• DJO promotes a work

environment free from

discrimination and unlawful

harassment.

• DJO is committed to maintaining

a business environment free

from the effects of drug and

alcohol abuse.

7

DEALING WITH COMPANY CONFIDENTIAL INFORMATION

After its employees, DJO’s most valuable asset is its proprietary information. If this information is improperly disclosed to competitors or others, that disclosure may severely impede or jeopardize the Company’s ability to conduct business.

Proprietary information includes, but is not limited to, employee information, research documents, computer files, manufacturing documents, clinical data, product information, business, financial and marketing plans or reports and other tangible or intangible materials or information. In short, any information or material produced by or for DJO in connection with its business is proprietary information and must be treated in a confidential manner.

DJO employees have access to information that is proprietary to the Company. In addition, with the advent of ever-changing

communication tools such as the internet, email, chat rooms, electronic message boards, etc. employees should take care to avoid disclosing confidential or proprietary information via electronic media.

If someone outside the Company requests information concerning DJO or its products, employees should refrain from responding unless and until the employee has received appropriate authorization to make such disclosures to the requestor. If an employee is contacted by outside business analysts, individual investors or media persons requesting information concerning the Company, its business activities or its products, the employee should direct the requestor to the DJO Legal Department.

Although DJO cooperates with government investigations, it also has important interests to protect. As a result, should an employee receive an inquiry from an outside attorney, investigator or law

enforcement officer regarding Company business, the employee should immediately contact a supervisor or the DJO Legal Department.

In addition, employees may possess, or come to possess, information that is proprietary to third parties, such as former employers, or DJO’s suppliers, customers and partners. Employees who possess such information have an obligation to respect its confidentiality and may not use or disclose the information without the consent of the third party.

Confidential Information

“Propriety information” is information that is the property of DJO and should be treated as confidential.

Employees must use extreme caution and exercise good judgment when discussing DJO, its products, data or plans with anyone outside the Company.

QUICK REFERENCE

• Information or material

produced by or for DJO

in connection with its

business must be treated in a

confidential manner.

• Employees should use

extreme caution and exercise

good judgment when

discussing DJO with anyone

outside of the Company.

8

Protected Health Information

HANDLING PROTECTED HEALTH INFORMATION

Certain Company employees, such as those individuals who process patient claims or supply DJO products to patients, have direct access to patient information. In order to comply with applicable privacy regulations, such as the Health Insurance Portability and Accountability Act (HIPAA) in the U.S. and to maintain the respect and trust of patients and the health care professionals with whom DJO does business, employees must safeguard patient Protected Health Information (PHI) from misuse, alteration, theft, fraud, unauthorized disclosure and unauthorized use.

The applicable law in many countries requires that the Company disclose patient information only for the purposes of treatment, payment and health care operations, unless patient consent has been obtained.

A copy of the Company’s Notice of Privacy Practices is posted on the DJO public website and employees are encouraged to review this document. Should an employee become aware of a potential unauthorized release or mishandling of PHI, that individual should immediately contact the DJO Corporate Compliance Department.

Employees with authorized access to PHI must protect this information not only from individuals outside the Company, but also from other Company employees whose duties do not require access to the information.

QUICK REFERENCE

• Protected Health

Information (PHI) is

individually identifiable

health information in any

form or media, whether

electronic, paper or oral.

• Employees must safeguard

patient PHI from misuse,

alteration, theft, fraud,

unauthorized disclosure

and unauthorized use.

• Any potential unauthorized

release of PHI must be

immediately reported

to the DJO Corporate

Compliance Department.

9

SIGNING ON BEHALF OF DJO

Correspondence, reports, and other documents that contain substantive opinions, conclusions, or determinations or that legally bind DJO must be signed by or under the control of DJO Senior Officers.

Before signing an agreement for DJO, be certain you have the legal authority to obligate the company and that you have obtained all required corporate authorizations.

SPECIAL OBLIGATIONS FOR DJO SENIOR OFFICERS

The Company’s Chief Executive Officer (“CEO”), Chief Financial Officer (“CFO”), Executive Vice Presidents, Business Unit Presidents, and such other DJO officers designated from time to time by the Board of Directors (“Senior Officers”) each bear a special responsibility for promoting integrity throughout the Company.

The Company is required to file periodic and annual reports with the U.S. Securities Exchange Commission and as such the Company and its Senior Officers are subject to a number of laws, rules and regulations regarding the disclosure of information material to its investors (holders of publicly–traded stock or debt), and the accurate reporting of its financial condition. The Senior Officers and other employees performing financial and accounting functions are subject to a Code of Ethics applicable to those who have responsibility for the conduct and supervision of the Company’s financial affairs.

Pursuant to this Code of Ethics, the Senior Officers are required to act at all times with integrity, avoiding actual or apparent conflicts of interest in personal and professional relationships.

As such, the Senior Officers are required to address any apparent conflicts of interest and promptly disclose to DJO’s Audit Committee the nature of any such conflict or material transaction which could give rise to a conflict.

Senior Officers are also required to provide full, fair, accurate, timely and understandable disclosure in reports and documents the Company files with the SEC and in other public communications. Finally, the Senior Officers are required to report any violations of the Code of Ethics to the Company’s Audit Committee.

Obligations for Senior Officers

QUICK REFERENCE

• Senior Officers bear a special

responsibility for promoting

integrity throughout the

company.

• Certain documents, such as

those that legally bind DJO,

must be signed by or under the

control of DJO Senior Officers.

10

INSIDER TRADING

Company employees are prohibited from trading in the stock or other securities of DJO while in possession of material, non-public information about the Company.

In addition, Company employees are prohibited from recommending that anyone else buy or sell stock or other securities of DJO on the basis of material, non-public information. Company employees who obtain material non-public information about another company in the course of their employment are prohibited from trading in the stock or securities of the other company while in possession of such information or recommending that others trade on the basis of such information.

Information is “material” if a reasonable investor would consider it important in a decision to buy, hold or sell stock or other securities; any information that would affect the value of stock or other securities should be considered material. Examples of information that is generally considered material include the following:

• Financial results or forecasts, or any information that indicates that a company’s financial results may exceed or fall short of forecasts or expectations;

• Important new products or services;

• Pending or contemplated acquisitions or dispositions, including mergers, tender offers or joint venture proposals;

• Possible management changes or changes of control;

• Pending or contemplated public or private sales of debt or equity securities or refinancings or repurchases of debt or equity securities;

• Acquisition or loss of a significant customer or contract;

• Significant write-offs;

• Initiation or settlement of significant litigation; and

• Changes in the Company’s auditors or a notification from its auditors that the Company may no longer rely on the auditor’s report.

Insider Trading

Information is considered “non-public” if it has not been made generally available to the public through a press release or other widespread distribution.

QUICK REFERENCE

• Rules against insider trading on

material non–public information

exist in most jurisdictions around

the world.

• Employees should seek guidance

if unsure whether information is

“non-public” or “material.”

11

ACCURATE RECORDING & REPORTING

It is important that all reports, records, documents or other information compiled in the performance of an employee’s duties be completed fully and accurately. This includes internal documents, like time sheets and expense reports, as well as documents prepared for external purposes, like clinical data, financial statements or environmental impact reports.

Accurate Recording & Reporting

Dishonest reporting of information to organizations or persons outside the Company may lead to criminal or civil liability for both the employee and the Company. Dishonest reporting includes both the failure to provide information needed to make a document complete and not misleading, as well as presenting information in such a manner as to distort its meaning or significance.

QUICK REFERENCE

• DJO is committed to

communicating with integrity,

to disclosing information in a

timely and appropriate manner

and to maintaining accurate

company books and records and

appropriate internal controls.

12

Fraud & Abuse

To avoid violating the AKS, or similar laws in other countries, it is important to remember that no program or practice involving remuneration to customers may have as part of its purpose to induce the writing of prescriptions, or the ordering or purchasing of products, unless such program or practice falls within one of the safe harbors.

FRAUD & ABUSE

Anti-Kickback Statute

The Federal Anti-Kickback Statute (“AKS”) in the U.S. establishes criminal as well as civil penalties for offering, paying, soliciting, or accepting a kickback, bribe, rebate or any other form of remuneration for ordering or purchasing a product or any service reimbursable by Federal or state health care programs, including Medicare. Because many DJO products are reimbursable by Medicare, the AKS is applicable to the Company’s sales and marketing practices. In addition to corporate penalties, the AKS provides that violators may be fined in their individual capacity and may receive jail terms.

False Claims Act

The False Claims Act (FCA) in the U.S. prohibits the knowing submission of false or fraudulent claims to the Federal government. Many other jurisdictions have also adopted FCAs or other laws that are similar to those found in the Federal FCA. Examples of a False Claim include, but are not limited to: filing a claim for services that were not rendered at all or were not medically necessary; submitting a claim containing information one knows to be false; or assisting a customer in submitting a false or fraudulent claim.

A person or entity found liable under the FCA is subject to a civil monetary penalty of between $5,550 and $11,000 per False Claim, plus three times the amount that the

government paid for each False Claim. In addition to fines and penalties, the courts can impose criminal penalties against individuals and organizations for willful violations of the FCA. The other jurisdictions that have adopted False Claims laws can also impose significant fines and penalties. The Company provides on-going education to the applicable employees and conducts regular audits to help ensure that claims are appropriately submitted to all payors, and are not in violation of the FCA.

United States Whistleblower Statute

The FCA allows anyone to bring a qui tam (whistleblower) action under the FCA. Whistleblowers are entitled to between 15 and 30 percent of any recovery, with the amount depending on whether or not the government decides to pursue the case.

The courts may reduce the whistleblower’s share of the proceeds if the courts find that the whistleblower planned and initiated the False Claim violation. Further, if the whistleblower is convicted of criminal conduct related to his role in the preparation or submission of the False Claims, the whistleblower will be dismissed from the civil action without receiving any portion of the proceeds. Anyone initiating a qui tam case will not be discriminated or retaliated against by the Company.

QUICK REFERENCE

• The Anti-Kickback Statute

prohibits anyone from

knowingly and willfully receiving

or paying anything of value to

influence the referral of Federal

health care program business.

• In the U.S., many states have

adopted state anti-kickback

statutes that have the same

penalties as the Federal Anti-

Kickback statute.

13

Manufacturing & Promotion

No public communication should be made with the intent of promoting products as safe and effective for any use before FDA and/or other appropriate regulatory agency approval is obtained, as required.

MANUFACTURING & PROMOTION OF PRODUCTS

In developing and manufacturing medical devices and other products, the Company has established and will comply with standards that meet or exceed regulations issued by the Food and Drug Administration or the laws and regulations of other applicable countries. In manufacturing its products, the Company will comply with all applicable laws and regulations, including those relating to the environment and occupational health and safety.

Promotional materials are considered “labeling” and are

regulated by the U.S. Food and Drug Administration (FDA) as well as internationally by Medical Device Directive 93/42/EEC for those products that are CE marked. Promotion of and claims made about products must be consistent with all applicable regulations. Similarly, the FDA has strict rules regarding the comparison of products.

Should an employee have concerns or questions related to the manufacturing or promotion of products, they should contact the DJO Legal Department.

QUICK REFERENCE

• DJO is committed to

producing products that are

safe and effective.

• DJO is committed to

providing information that is

truthful and balanced based

on valid scientific evidence

and sound clinical medicine.

14

Fair Dealing

FAIR DEALING

Antitrust and competition laws are generally designed to promote fair competition and ensure that businesses compete on the basis of quality, price and service. Generally, U.S. and International laws prohibit agreements or actions that might unreasonably restrain competition or bring about a monopoly (in the U.S.) or abuse a dominant market position (in the EU). Individual European countries, Japan, Canada, and Australia and a number of other countries have similar laws. These laws may be known as antitrust, monopoly, fair trade or cartel laws.

Listed on the next page are several practices that in the past have been found to violate antitrust statutes. Violations of these guidelines could create legal liability for the Company, as well as for the individual employee.

This list is not exhaustive and all employees are encouraged to seek advice from the DJO Legal Department if they are about to engage in, or are confronted with, a situation that they believe may violate antitrust laws.

The purpose of such laws is to prevent unreasonable interference with the functioning of a competitive market system in a way that harms consumers.

QUICK REFERENCE

• Employees must deal fairly

with the Company’s customers,

suppliers, competitors,

independent auditors, and

other employees.

• Employees may not take

advantage of anyone through

manipulation, concealment,

abuse of privileged information,

misrepresentation of material

fact, or any other unfair dealing

or practice.

• Competitors are not permitted

to agree among themselves to

fix or control prices.

• Employees should avoid

disparaging competitors

to customers.

15

Dealing with Competitors

Competitors are not permitted to agree among themselves to fix or control prices. To avoid an appearance of collusion, employees should never engage in communications with a competitor about:

• price or pricing policies;• bids, costs, or discounts;• promotions;• terms of sale, credit terms,

freight charges or royalties,

Employees should refrain from engaging in conversation or agreements that might give the impression of collaboration with a competitor to:

• divide up customer lists, sales territories, or a particular customer’s business;

• control the rate of production of a product;

• not to sell to particular individuals or firms;

• not to buy from particular individuals or firms.

Should an employee be asked by a competitor to enter into an illegal or questionable agreement, or to share information about the Company’s practices, the employee should take the following actions:

• Tell the competitor that such discussions may be illegal and potentially criminal;

• Tell the competitor never to discuss the subject with you again.

In addition, the employee should immediately report the incident to the DJO Legal Department.

Obligations Relating to Prior Employment

In their previous employment, employees may have learned, or been given access to, confidential information belonging to their employer and its clients or suppliers, and may have entered into certain enforceable agreements. Employees are required to honor any such agreement and abide by any applicable laws, including those regarding: (1) disclosure or use of confidential information; (2) hiring/soliciting from the prior employer, and; (3) soliciting the prior employer’s customers.

Dealing with Customers

Agreements in which the Company limits the individuals or firms from whom it will purchase goods or services, or attempts to limit its customers’ rights to purchase goods and services from others, may be illegal. In addition, attempts to tie the purchase of one product to an agreement to purchase another product may also be illegal. Moreover, except in some circumstances, it is illegal for the Company to have an agreement or understanding with distributors about the prices the reseller will charge its customers.

As a general practice, employees should avoid disparaging competitors to customers. Statements concerning competitors that cannot be substantiated may violate unfair competition statutes. Employees should never urge a customer to violate a contract with a competitor.

Dealing with Competitors

It is illegal to agree with a competitor to divide up sales territories or to allocate customers.

16

Conflicts of Interest

CONFLICTS OF INTEREST

Examples of such conflicts include, but are not limited to:

• misuse of the employee’s position within the Company for personal or family members’ gain;

• outside employment with a competitor of the Company;

• referral of DJO business to a firm controlled by any DJO employee or family member;

• personal acquisition of any property with knowledge that the Company, were it aware of the opportunity, would wish to acquire the same or similar property;

• soliciting or receiving greater than nominal gratuities from customers or suppliers of the Company.

In some international business transactions, it is customary and lawful for business leaders in a host country to give gifts to Company employees. These gifts may be of more than nominal value and under the circumstances returning the gifts or paying for them may be an affront to the giver. In such a situation, the gift must be reported to the employee’s supervisor and the DJO Legal Department.

In some cases, the gift may be retained by the Company, at its sole discretion, and not the individual. Any exchange of gifts must be conducted so that there is no appearance of impropriety. Gifts may be given only in compliance with applicable law.

A conflict of interest exists any time an employee has a personal interest that conflicts with the best interests of DJO.

QUICK REFERENCE

• A conflict of interest is

created when an activity,

interest (financial or

personal) or association

of an employee directly

or indirectly compromises

his or her independence

or judgment, causing the

interests of the employee or

another person to influence

a business decision

inappropriately.

• Employees must avoid

conflicts of interest

between his or her personal

interests and the interests

of DJO.

17

Dealing with Suppliers

DEALING WITH SUPPLIERS

In dealing with suppliers, it is DJO policy to obtain the goods and services it needs to conduct business fairly and without discrimination, and in such a manner as to ensure that it receives the highest quality at the most reasonable cost.

Therefore, employees may not accept any gift, entertainment or favor from a supplier in circumstances that appear to create an obligation on either the part of the employee or the part of the Company. However, employees may accept gifts and business courtesies, including meals and entertainment,

so long as they are commonly accepted business courtesies, not excessive in value, and given and accepted without an express or implied understanding that the recipient is in any way obliged by acceptance of the gift.

Gifts that are excessive in value should not be accepted without the approval of the employee’s immediate manager or supervisor and the DJO Legal Department. Employees must never ask for gifts or entertainment from people doing business with DJO.

QUICK REFERENCE

• Employees may not accept any

gifts from a supplier if it appears

to create an obligation.

• DJO is committed to dealing

with its suppliers fairly and

without discrimination.

18

DEALING WITH GOVERNMENTS

What may generally be considered acceptable practice in the commercial business environment, such as providing entertainment or gifts of nominal value, may be entirely unacceptable, and in fact may violate federal, state or local laws, when dealing with government officials or individuals who act on the government’s behalf.

As a general guideline during the course of procurements involving governmental entities, employees and others competing for that procurements must not improperly influence the decisions of, or

obtain restricted information from, government officials, including those who act on the government’s behalf. Specifically, employees must not undertake directly or indirectly any of the following activities during government procurements:

• Discuss or offer employment or business opportunities that could personally benefit procurement officials;

• Solicit or obtain proprietary or source selection information;

• Offer or provide gratuities in connection with procurement activities.

International Boycotts

U.S. anti-boycott laws apply to economic boycotts of other countries that are not sanctioned by the U.S. These laws require U.S. companies and all their controlled subsidiaries to report most requests to support an unsanctioned boycott, whether the requests are verbal or in writing. As a result, employees must report any suspicious requests or contract terms to the DJO Legal Department.

Dealing with Governments

Employees must be aware of and adhere to the relevant laws and regulations governing relations between government customers and suppliers.

QUICK REFERENCE

• Employees must be aware of

and adhere to the relevant

laws and regulations governing

relations between government

customers and suppliers.

• During the course of

government agency

procurement, employees and

others competing for that

procurement should not try

to improperly influence the

decisions of, or obtain restricted

information from, government

procurement officials,

including those who act on the

government’s behalf.

19

POLITICAL CONTRIBUTIONS & IMPROPER PAYMENTS

Political Activities

Laws of certain jurisdictions prohibit the use of company funds, assets, services or facilities on behalf of a political party or candidate. To ensure compliance with applicable laws, consent must be obtained from the DJO Legal Department prior to committing any company time or resources for political activities.

Foreign Corrupt Practices

The laws of many countries, including the U.S. Foreign Corrupt Practices Act (FCPA), and DJO policy prohibit the Company or employees

from directly or indirectly giving or offering anything of value to government officials or officials of public international organizations for the purpose of gaining business or favorable government action. Payment need not take the form of cash to be prohibited. Determining what gift or payment may be permitted may involve difficult legal judgments. In addition, in a number of countries there are absolute prohibitions or very tight restrictions on gifts for any purpose to members of the national legislative body, their families and staff. In every case, DJO is required to maintain accurate records and internal controls.

Prohibited payments include, but are not limited to:

• cash, gifts and free samples;

• use of automobiles and aircraft;

• payment of nonessential travel and entertainment expenses;

• overbilling of sales with the expectation that part of the sales price will be returned to the buyer;

• making contributions to charities or other organizations chosen by an official.

It is important to be aware that the mere offer to pay or make such payments is prohibited regardless of whether they are accepted or any payment is actually made.

Contributions & Improper Payments

QUICK REFERENCE

• DJO will not reimburse employees for any personal political contributions.

• The Company complies with the United States Foreign Corrupt Practices Act and the United Kingdom Bribery Act; employees must not, directly or indirectly, offer, pay or receive bribes.

• Employees may not pay, offer to pay, or authorize the payment of anything of value to any foreign government official, government staff member, political party or political candidate in an attempt to obtain or retain business or to otherwise influence a person working in an official governmental capacity.

20

Contributions & Improper Payments (cont.)

The UK Bribery Act

The UK Bribery Act introduces a new crime of “failure to prevent” bribery which means that companies unable to demonstrate that they have implemented “adequate procedures” to prevent corrupt practices within their ranks or by third parties on their behalf, could be exposed to unlimited fines. Simply having a UK presence (subsidiary, office or operations) will create jurisdiction.

The UK Bribery Act applies to both UK companies and foreign companies with operations in the UK, such as DJO, even if offenses take place in a third country and are unrelated to UK operations. This means that the relevant criminal act can occur outside the UK and persons or companies in the UK can be liable. For example, if a US

company has a UK branch and engages in bribery in Asia, that US company may have liability under the Bribery Act and could be prosecuted in the UK for failing to prevent bribery.

Bribing and Accepting Bribes

The UK Bribery Act criminalizes the act of bribing another person, as well as the act of receiving a bribe. These offenses are defined to include offering, promising or giving (or requesting, agreeing to receive or accepting) a financial or other advantage with the intention that a function or activity will be performed by or on behalf of a body of persons. As a result, unlike the FCPA, the UK Bribery Law prohibits private as well as public sector bribes.

Facilitation Payments

”Facilitation payments,” also known as “expediting payments” or “grease payments,” are bribes paid to induce foreign officials to perform routine functions they are otherwise obligated to perform. Examples of such routine functions include issuing licenses or permits and installing telephone lines and other basic services. Facilitation payments are prohibited under the UK Bribery Act and DJO policy.

It is the Company’s policy to comply with all applicable laws prohibiting bribery which are in place in the countries in which the Company does business or seeks to do business. Any question as to what law applies in any particular circumstances or the scope of any law should be directed to the DJO Legal department.

QUICK REFERENCE

• Facilitation payments are

prohibited under DJO Policy.

• DJO is expected to have

procedures in place that

are designed to prevent its

employees, intermediaries,

and subsidiaries from being

involved in bribery.

21

Protection & Proper Use of DJO Property and Assets

PROTECTION & PROPER USE OF DJO PROPERTY AND ASSETS

DJO assets, both tangible and intangible, are to be used only for legitimate business purposes of the Company and only by authorized employees. Intangible assets include intellectual property as described below. Unauthorized alteration, destruction, use, disclosure or distribution of DJO assets violates Company policy. Theft or waste of, or carelessness in using Company assets has a direct adverse impact on DJO’s operations and profitability and will not be tolerated.

Employees found to be engaging in, or attempting, theft of any property of the Company, including documents, equipment, intellectual property, personal property of other employees, cash or any other items of value may be subject to immediate dismissal and possible criminal proceedings against them.

DJO Property and Facilities

All employees must take appropriate actions to protect the Company’s

assets and ensure their efficient use for legitimate business purposes. Employees may not solicit or distribute any non-work-related literature for any purpose during working time or the working time of the person(s) being solicited. Employees may not distribute any such literature at any time in any work area. In addition, selling, trading, or bartering of services or merchandise to others is prohibited on DJO premises during work time.

Consistent with applicable law, DJO may permit a small number of solicitations for charitable causes, as determined in advance by the Company. Participating in or soliciting for organized or commercial lotteries or other gaming or gambling activities is prohibited.

This policy, however, should not be construed as prohibiting or restricting solicitation/distribution that is otherwise permissible under applicable law.

DJO property and resources must be used only for the proper advancement of our business and not for personal gain, nor for any fraudulent purpose

QUICK REFERENCE

• All employees have a

responsibility to report any

theft or attempted theft to

DJO management.

• Employees must take

appropriate actions to protect

the Company’s assets and

ensure their efficient use for

legitimate business purposes.

• Employees should have no

expectation of privacy when

using DJO resources such

as company equipment and

computer or telephone systems.

22

Employees may not use the Company’s communications and messaging tools (including the Internet and Intranet) to send, retrieve or store harassing, threatening, derogatory, defamatory or obscene messages or for any illegal purpose or in any manner that is contrary to the Company’s policies or the standards embodied in this Code.

DOCUMENT RETENTION

Various applicable laws and regulations require retention of certain DJO records, including electronic records, for specific periods of time. The subject matter of the record – not its form – determines the appropriate retention period. Employees must not destroy records relevant or potentially relevant to pending or expected litigation, tax positions, audits, or investigations. If DJO receives a subpoena to produce such records, employees must not in any way modify or destroy such records.

Unauthorized destruction or falsification of any relevant or potentially relevant records may lead to prosecution for obstruction of justice. If in doubt about the legality or propriety of destroying

or changing any document or other records, contact the DJO Legal or Compliance Department.

The Company provides computers, voice mail, electronic mail (email), telephone, mobile messaging, or other wireless communication devices, and Internet access to certain employees for the purpose of achieving the Company’s business objectives. As a result, subject to local applicable laws, the Company has the right to access, reprint, publish, or retain any information created, sent or contained in any of the Company’s communications and messaging tools (including the Internet and Intranet).

DJO reserves all rights, to the fullest extent allowed by applicable law, to inspect the company’s facilities, property (e.g., computers, wireless devices), records and systems,

including electronic systems, and the information contained in them, with or without advance notice to employees.

While DJO may from time to time take or use photographs, videos or audio recordings of its employees for business purposes in compliance with applicable law, employees may not take or distribute photographs, videos or audio recordings of DJO employees, unless it is clear they consent. Photographing, videotaping or audio recording employees without their awareness or consent may jeopardize their privacy and may violate applicable laws.

Document Retention

23

In general, copyright law prohibits the use of copyrighted work without the consent of its owner. Unless employees know that a work is owned by the Company or is not protected by copyright law, employees should not make copies of, or resell or transfer copyrighted publications, including software, manuals, articles, books, and databases being used by DJO, that were created by another entity and licensed to the Company, unless authorized to do so under the applicable license agreement.

In no event should employees load or use, on any DJO computer, any software, third party content or database without receiving the prior permission of their supervisors

and the Information Technology Department. Employees must refrain from transferring any data or information to any Company computer other than for Company use.

Employees may use a handheld computing device or mobile phone in connection with work for the Company, but must not use such device or phone to access, load or transfer content, software or data in violation of any applicable law or regulation or without the permission of the owner of such content, software or data.

Any question as to what is permitted in this regard should be raised with the DJO Information Technology Department.

Intangible Assets

To the extent allowed by applicable law, the Company is legally entitled to all rights in ideas, inventions and works of authorship relating to its business that are made by employees during the scope of their employment with the Company or using the resources of the Company (“Employee Developments”).

Similarly, to the extent allowed by applicable law, employees are required, as a condition of employment, to promptly disclose all employee ideas to their supervisor, and to execute the necessary documentation to transfer all Employee Developments to DJO to evidence its ownership, or to obtain legal protection for them.

Employees must refrain from transferring any data or information to any Company computer other than for Company use.

Document Retention (cont.)

24

SAFETY, THE ENVIRONMENT & SUSTAINABILITY

The Company conducts business in a manner that meets or exceeds regulations such as those established by the Occupational Safety and Health Administration (OSHA). Additionally, DJO has invested in disaster and other emergency preparedness training and routinely conducts drills.

The Company ensures employees receive training on proper ergonomics and handling of hazardous materials to prevent injuries, damage to products or equipment and avoid environmental contamination.

ENVIRONMENT & SUSTAINABILITY

DJO has a strong commitment to preserving our environment; it is Company policy to comply with all applicable environmental laws. In the absence of specific laws and regulations, DJO will attempt to have its decisions and actions made in such manner as to best protect the public and the environment. DJO has been on its ‘green and sustainability” journey since 2007 and issued its first Sustainability

Report in 2011. Some of the ways that DJO supports sustainability and the environment include:

• Protecting our environment by reducing, reusing and recycling;

• Developing new products with consideration to environmental concerns, such as design for recyclability and eliminating or minimizing substances of concern;

• Reducing our carbon footprint, water withdrawal and weight of landfill bound waste; and

• Measuring, monitoring and reporting our progress on these objectives.

DJO takes workplace safety very seriously and through continuous improvement, is committed to creating a safe work environment for its employees.

Safety, The Environment, and Sustainability

QUICK REFERENCE

• Employees should help

promote a safe and healthy

work environment.

• Employees should be aware

of and seek to improve the

environmental impact of their

work activities.

• Employees must promptly

report accidents, incidents

of non-compliance, or any

other matter posing a threat

to safety, health or the

environment.

25

We must not lose sight of our fundamental commitment to doing business the right way.

DO THE RIGHT THING

26

The Senior Officers and key management individuals of each of the business units of the Company are responsible for ensuring that his or her employees understand and comply with this Code, and for creating a work environment in which compliance is expected and rewarded.

Questions concerning this Code may be directed to the Senior Officer and/or key management individuals of a DJO operating subsidiary, the DJO General Counsel, DJO SVP of Corporate Compliance, or the DJO Human Resources Department.

Any violation of this Code should be reported immediately by contacting a supervisor, the General Counsel, the DJO SVP of Corporate Compliance or the DJO

Human Resources Department. As an alternative, a violation may be reported by calling the DJO Compliance Hotline (refer to page 27 for your country-specific hotline number).

The Company takes all reports of alleged violation of these policies seriously. Violation of a policy, retaliation against any individual for reporting a violation, or failure to otherwise comply with these policies will not be tolerated and will result in disciplinary action, up to and including employee termination, or termination of a business partnership.

Senior Officers, key management individuals and appropriate employees will be required, consistent with applicable law, to periodically confirm in writing they

have read, understand, and are complying with the Code and that they are not aware of any violations of these policies or have properly reported all violations.

Thank You for Your Support!

Any Questions?

27

No Rights Created The DJO Code of Conduct is not intended to confer any special rights or privileges upon specific individuals, provide greater or lesser rights under applicable law or entitle any person to remain employed by DJO for any specific period or under specific terms and conditions. Unless contrary to applicable law or the terms of a written contract executed by an appropriate officer of DJO, employment at DJO is for no definite period and may – to the extent permitted by local law – be terminated at any time by the company or by an employee for any reason or no reason at all, with or without notice. The DJO Code of Conduct is not a contract, and DJO retains the right to unilaterally modify the Code at any time to the extent permitted by local law, without advance written notice.

INTERNATIONALCOUNTRY ACCESS CODE TOLL FREE NUMBER LANGUAGEAustralia 1-800-881-011 866-614-5869 English

Australia 1-800-551-155 866-614-5869 English

Austria 0-800-200-288 866-614-5869 German

Belgium 0-800-100-10 866-614-5869 Dutch

Denmark 800-100-10 866-614-5869 Danish

Finland 0-800-11-0015 866-614-5869 Finnish

France 0-800-99-0011 866-614-5869 French

France 0805-701-288 866-614-5869 French

Germany 0-800-225-5288 866-614-5869 German

Hong Kong 800-96-1111 866-614-5869 Cantonese

Hong Kong 800-93-2266 866-614-5869 Cantonese

Ireland 1-800-550-000 866-614-5869 English

Italy 800-172-444 866-614-5869 Italian

Mexico 01-800 288-2872 866-614-5869 Spanish

Mexico 01-800-112-2020 866-614-5869 Spanish

Netherlands 0800-022-9111 866-614-5869 Dutch

Norway 800-190-11 866-614-5869 Norwegian

South Africa 0-800-99-0123 866-614-5869 English

Spain 900-99-0011 866-614-5869 Spanish

Sweden 020-799-111 866-614-5869 Swedish

Switzerland 0-800-890011 866-614-5869 French

United Kingdom 0-800-89-0011 866-614-5869 English

United Kingdom 0-500-89-0011 866-614-5869 English

DJO COMPLIANCE HOTLINES

DJO is firmly committed to conducting its business in an ethical and legal manner in all countries in which it does business. Towards that end, DJO has contracted with The Network, a third-party service provider that specializes in compliance hotline services, to take reports submitted to DJO’s Compliance Hotline.

The hotline is available 24 hours a day/7 days a week. DJO has one (1) hotline number for individuals based in the U.S., and multiple international numbers for individuals based in locations outside of the U.S. The hotline is available for employees, customers, independent agents and vendors who wish to file a report. Please be aware that DJO prohibits retaliation against any individual who, in good faith, reports a potential compliance violation.

DJO U.S. Confidential Compliance Hotline

The U.S. Hotline provides an anonymous method, if an individual so chooses, to report illegal, unethical or other potentially inappropriate business situations to DJO management. The U.S. DJO confidential compliance hotline number is 1-877-888-0002.

DJO International Confidential Compliance Hotline

The international Hotline provides an avenue for an individual to bring reports of certain types of misconduct to the attention of DJO management. The Network is based in the U.S. but provides call center representatives who are fluent in the language of the country where the international caller is located. To contact the Hotline from your location, please use the appropriate access code listed by country.

DJO Global Compliance Hotlines

©2017 DJO, LLC

DJO, LLC I A DJO Global CompanyT 800.336.6569 D 760.727.1280 F 800.936.6569

1430 Decision Street I Vista, CA 92081-8553 I U.S.A.DJOglobal.com

00-0807 Rev. D

• Is it illegal?

• Would you feel uncomfortable if everyone knew what you did?

• Is the decision or action I am going to take in line with our core values and this code of conduct?

• Have I understood the risk and the possible implications of what I am doing?

• If necessary, have I sought advice to help me make an informed decision?

• Am I leading by example?

• Have I considered any potential impact on DJO’s reputation?

• How will I feel if the action I take today is featured in the newspaper or on television tomorrow?

In your everyday business activities,ASK YOURSELF