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NOVOCOL HEALTHCARE INC’S COMMITMENT TO ETHICS AND COMPLIANCE
Novocol Healthcare, Inc. is committed to the highest standards of ethical conduct and corporate compliance. Based upon our good faith understanding and to the best of our knowledge, we have established a Comprehensive Compliance Program that is reasonably designed to prevent and detect violations of our Standards of Conduct and applicable laws and regulations. Our Program is tailored to the size, organizational structure, operational activities and resources of Novocol Healthcare, Inc. to meet compliance goals consistent with our corporate ethics and with the statutory requirements of California Health and Safety Code §§119400-119402.

The Novocol Healthcare, Inc. Comprehensive Compliance Program recognizes that compliance is dynamic. It provides for revisions when necessary to reflect changes in company operations, the Compliance Program Guidance for Pharmaceutical Manufacturers published by the Office of Inspector General for the U.S. Department of Health and Human Services, the PhRMA Code on Interactions with Health Professionals, and applicable laws.

To the best of our knowledge, we are in material compliance with the Comprehensive Compliance Program as described, meaning that we have established the elements outlined and have set up procedures to implement the program’s requirements. This declaration is made as of March 10, 2018.

To view a copy of our Comprehensive Compliance Program, click on the following link Novocol Healthcare's Comprehensive Compliance Program

Our Compliance Officer can by reached at (800) 647-0643, if you have any questions.

Eric PENROSE
Compliance Officer