Medtronic Comprehensive Compliance Program

I. Introduction

Medtronic is committed to establishing and maintaining an effective compliance program in accordance with the Compliance Program Guidance published by the Office of Inspector General, U.S. Department of Health and Human Services (the "HHS-OIG Guidance"). Our Compliance Program, established by our Board of Directors in conjunction with Medtronic senior management, is one of the key components of our commitment to the highest standards of ethical practice.