Codes of Business Conduct and Ethics Summary of Changes

Code of Business Conduct & Ethics

Code of Business Conduct & Ethics




On October 21, 2021, the Board of Directors of Masimo Corporation (“Masimo”) approved a revised Code of Business Conduct and Ethics (as revised, the “Code”) that amended and restated Masimo’s prior Code of Business Conduct and Ethics (the “Prior Code”). The Code supersedes the Prior Code.

None of the amendments reflected in the Code constituted or effected a waiver of any provision of the Prior Code applicable to Masimo’s principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions. The following is a summary overview of the material amendments to the Prior Code:

1. Persons Subject to the Code

The Prior Code has been amended to clarify that, in addition to applying to all of Masimo’s employees, directors and officers, the Code applies to persons that conduct business on Masimo’s behalf such as distributors, sales agents and other third party representatives of Masimo worldwide.

2. International Business Laws

The Prior Code has been amended to expand the discussions regarding U.S. Sanctions, U.S. Export Controls and U.S. Antiboycott Laws.

3. Research and Development Compliance

The Prior Code has been amended to expand the list of requirements and standards applicable to the development of medical device products to include design controls, good manufacturing practices, labeling control/approval, reporting requirements, product registrations, and the approval and distribution of Masimo products.

4. Anti-Corruption

A new, separate section covering corruption has been added to the Prior Code, which provides for the following:

  • Masimo is committed to conducting business ethically and legally;
  • Masimo will not tolerate corruption as a means of furthering Masimo’s business;
  • persons subject to the Code may not offer or provide anything of value in order to improperly induce or reward an individual or entity for recommending, purchasing, or using Masimo products or services;
  • gifts, meals, entertainment, and other items of value may not be offered or provided as an illegal inducement or reward;
  • persons subject to the Code must never attempt to improperly influence a government official;
  • some laws and regulations in the countries in which Masimo does business have prohibitions or limits on giving items of value to government officials; and
  • third parties (for example, distributors, agents and consultants) who act on Masimo’s behalf are subject to the same anti-corruption restrictions as persons subject to the Code, and persons subject to the Code may not ask, encourage or permit a third party to do something that such person is prohibited from doing himself or herself.

5. Treatment with Fairness and Respect; Workplace Health & Safety

The Code amends the classes of employees who are protected from discrimination to provide that Masimo does not tolerate discrimination against applicants or employees based on:

  • race,
  • color,
  • religion,
  • sex,
  • age,
  • disability,
  • national origin,
  • veteran status,
  • genetic information,
  • citizenship status, or
  • any other class or category protected under applicable law.

If you have a question as to whether an activity is restricted or prohibited, seek assistance from Masimo’s Legal department before taking any action, including giving any verbal assurances that might be regulated by international laws.

6. Electronic Communications

A discussion regarding the proper use of electronic communications has been added to the “Protection and Proper Use of Company Assets” Section of the Code.

7. Data Privacy

The Prior Code has been amended to include a discussion of Masimo’s commitment to data protection, including:

  • personal information should only be collected when needed and in accordance with applicable laws and Masimo’s policies;
  • information should be protected from attack, damage or unauthorized access; and
  • personal information should only be shared with others when there is a legitimate business or legal need to do so.

The foregoing summary of the material amendments to the Prior Code does not purport to be complete and is qualified in its entirety by reference to the full text of the Code, as may be amended or restated from time to time, which is available on Masimo’s website at