The twiist™ Automated Insulin Delivery (AID) System is for people with type 1 diabetes, 6 years of age and above, available with a prescription, only in the U.S. Visit twiist.com/safety for important safety information.
Sequel Med Tech is committed to conducting business with integrity, transparency, and in full compliance with applicable federal and state laws and regulations. As such, we have developed and implemented a comprehensive compliance program (“Program”) designed to prevent and detect violations of law, regulations, and company policies, and to promote an organizational culture that encourages ethical conduct and compliance with all healthcare requirements.
Our Program has been developed and supported by our senior management and is consistent with the principles set forth in the Compliance Program Guidance published by the Office of Inspector General, U.S. Department of Health and Human Services and the AdvaMed Code of Ethics on Interactions with Health Care Professionals.
We have described below the fundamental elements of our Comprehensive Compliance Program. In accordance with the voluntary standards established by the HHS-OIG Guidance, we have tailored our Compliance Program to fit the unique environment and size of Sequel and continually update our Compliance Program to address changing requirements.
Written Standards
Sequel Med Tech maintains written policies and procedures that support compliance with applicable laws and promote ethical, responsible business practices and interactions. Our Code of Conduct translates our values, legal requirements, and internal standards into practical guidance for employees to support sound decision-making.
Sequel Med Tech also maintains policies covering meals and travel, educational grants, sponsorships and exhibits, and interactions with healthcare professionals. These policies require strict adherence to all applicable laws and regulations.
Compliance Officer
Sequel Med Tech has appointed a Compliance Officer as the main contact for all compliance matters. This officer oversees the creation, execution, and ongoing review of Sequel Med Tech’s Compliance Program.
Sequel Med Tech is committed to ensuring that the Compliance Officer has the authority, independence, and resources necessary to exercise independent judgment and to effectuate change within the organization when needed.
Training and Education
Education and training are fundamental to ensuring that employees clearly understand and adhere to Sequel Med Tech’s standards, policies, and legal obligations. Sequel Med Tech maintains an Ethics and Compliance training program, which includes required testing and certifications for applicable employees.
Communication
Sequel Med Tech encourages the prompt reporting of any known or suspected violations of the Code of Conduct, company policies or procedures, or applicable laws and regulations. Reports may be made to supervisors, Human Resources (for HR-related matters), or the Compliance and Legal functions.
Sequel Med Tech provides a confidential reporting mechanism to allow employees and other parties to raise concerns in good faith. Reports are treated as confidential to the extent reasonably possible.
Retaliation against any individual who raises a concern in good faith is strictly prohibited and will not be tolerated.
Auditing & Monitoring
The Compliance department at Sequel Med Tech is empowered to audit any matters they find necessary and regularly reviews how well the organization follows its policies and procedures. We continuously assess our compliance programs to identify new or emerging risks and take action to address them.
Responding to Violations of the Compliance Program
Sequel Med Tech reviews and investigates all reports of potential violations. Should an investigation determine that corrective measures are necessary, the company will implement suitable actions, which may include disciplinary measures up to and including termination of employment. Although each case is handled individually, appropriate disciplinary action is always considered to prevent further issues.
Sequel Med Tech may, at its discretion, refer specific matters to the appropriate external authorities.
Corrective and Preventative Action
Sequel Med Tech’s Compliance Program is designed to detect and prevent conduct that may be inconsistent with the requirements of policy, regulations, or applicable laws and regulations. Our Compliance Program requires prompt response to potential misconduct, appropriate discipline, evaluation of any policy or control weaknesses, and action to prevent recurrence.
Annual Spending Limit
Sequel has established an annual limit of $2,500 for certain promotional materials, meals, and educational items that may be provided to California healthcare professionals pursuant to the requirements of CaliforniaHealth & Safety Code § 119402 (S.B. 1765).
Our annual spending limit does not include payments for legitimate services provided under consulting agreements, research contracts, or clinical trials, as permitted by law or the AdvaMed Code of Ethics.
Declaration
As of the date of this declaration to the best of our knowledge, Sequel Med Tech is in compliance with its Compliance Program and the provisions of the California Health and Safety Code § 119402 in all material respects. Last update: February 26, 2026.
A copy of this document may be obtained by calling 888-673-7835.
The twiist™ Automated Insulin Delivery (AID) System is for people with type 1 diabetes, 6 years of age and above, available with a prescription, only in the U.S. Visit twiist.com/safety for important safety information.
