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Global Business Ethics and Compliance

The Global Business Ethics and Compliance Program is dedicated to ensuring that our business is conducted with integrity and is compliant with applicable laws. This program is led by the Global Business Ethics and Compliance Officer, with guidance from the Global Business Ethics and Compliance Committee. They are supported by regional compliance officers and committees. The program consists of the following key elements:

The ApoPharma Code of Conduct and Business Ethics provides guidance to employees regarding the ethical, legal and compliance principles of the company. The Code of Conduct and Business Ethics is supplemented by various compliance policies, procedures and processes for individual business functions.

ApoPharma has established a maximum annual aggregate dollar limit of $2,500 for gifts, promotional materials, and related activities provided to health care professionals. This limit is an annual limit, not a goal or average, and the amount spent per healthcare professional is anticipated to be substantially less than this maximum amount. This limit does not include payments for bona fide services and similar payments as described in industry marketing codes. Waiver of the limit would require the approval of the Global Business Ethics and Compliance Officer.
Training sessions and educational materials about expectations for compliant and ethical behavior of employees.
Communication channels and tools for employees, customers and vendors to report concerns or misconduct, anonymously and without reprisals for employees (e.g., the Global Business Ethics and Compliance Helpline, www.ApoSpeaks.com).
Systems and procedures to assess adherence to the Code of Conduct and other compliance related matters, and to identify opportunities for enhancing ethical behaviours.
Taking appropriate action to validate and address issues, when concerns or allegations about misconduct or non-compliance arise.
To our knowledge as of the date of this declaration, ApoPharma is in compliance with our Global Business Ethics and Compliance Program, as well as relevant applicable national, federal and state laws (including but not limited to California Health & Safety Code sections 119400-119402) and industry standards relating to the marketing and promotion of our products.

Copies of this declaration and the ApoPharma Compliance Program may be obtained by calling 1.833.401.7715.

June 1, 2018