High-Level Conflict-Control Policies

1. Conflict Disclosure Policy

HyperFlex will disclose physician ownership, board roles, consulting relationships, training relationships, or other material financial relationships where relevant and appropriate.

For patients, disclosure should be made when a physician with a financial relationship to HyperFlex recommends, uses, or discusses HyperFlex products in connection with patient care.

For hospitals, surgery centers, and other facilities, disclosure should be made where a physician-owner or physician consultant practices at the facility, trains at the facility, or may be associated with the facility’s evaluation or use of HyperFlex products.

Disclosures should be clear, understandable, and documented where practical.

2. Clinical Independence Policy

All clinical decisions involving HyperFlex products must be based solely on the treating physician’s independent medical judgment and the patient’s individual clinical needs.

HyperFlex does not require, request, or encourage any physician to use, recommend, order, or select HyperFlex products except where the physician independently determines that the product is clinically appropriate.

No ownership interest, board role, consulting role, training opportunity, or other financial relationship with HyperFlex may influence patient care or product selection.

3. No Volume/Value Compensation Policy

HyperFlex will not compensate any physician based on:

  1. Sales volume.
  2. Procedure volume.
  3. Product use.
  4. Referrals.
  5. Territory revenue.
  6. Facility purchasing decisions.
  7. Commissions.
  8. Royalties tied to product use.
  9. Other volume- or value-based metrics.

Any physician compensation must be for legitimate services actually provided and must not be intended to reward, induce, or influence referrals, product use, product selection, or purchasing activity.

4. Training Compensation Policy

HyperFlex may compensate physicians for legitimate education, training, advisory, and clinical support services.

All such arrangements should be:

  1. Documented in writing.
  2. Based on a legitimate business need.
  3. Paid at fair market value.
  4. Supported by a statement of work or similar written description.
  5. Supported by time records, attendance records, or other reasonable documentation.
  6. Unrelated to sales volume, product use, procedure volume, referrals, or purchasing decisions.

Training compensation must not be used as disguised sales compensation or as a reward for using or recommending HyperFlex products.

5. Facility Purchasing Firewall Policy

A physician-owner, board member, consultant, or trainer affiliated with HyperFlex should not participate in purchasing, pricing, contracting, supply-chain, or procurement decisions involving HyperFlex products at facilities where the physician practices.

For Dr. Geldwert specifically, HyperFlex’s policy is that he does not participate in facility purchasing, pricing, contracting, procurement, or supply-chain decisions involving HyperFlex products at hospitals or surgery centers where he practices.

HyperFlex will manage facility relationships directly through appropriate company personnel and will not use a physician’s clinical role at a facility to improperly influence purchasing decisions.

6. Marketing Review Policy

HyperFlex will review Joe-related and physician-related promotional, educational, and marketing content for accuracy, appropriate disclosure, and consistency with approved company messaging.

Marketing content should not:

  1. Misstate the physician’s role or financial relationship.
  2. Suggest that patients are required to use HyperFlex.
  3. Imply that treatment decisions are financially motivated.
  4. Overstate outcomes or minimize risks.
  5. Encourage patient steering based on physician ownership or financial interest.

Where appropriate, marketing content should disclose the physician’s relationship with HyperFlex and make clear that treatment decisions remain based on independent clinical judgment.

7. Open Payments Procedure

HyperFlex will evaluate physician ownership interests and transfers of value for reporting under Open Payments and other applicable transparency requirements.

HyperFlex will report physician ownership, fair-market-value training payments, education payments, consulting payments, travel, meals, and other reportable transfers of value where required.

Physicians working with HyperFlex are expected to provide reasonable information needed for accurate reporting.

HyperFlex will maintain records supporting Open Payments determinations, including ownership information, payment records, service descriptions, and related documentation.