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Declaration Under Cal. Health & Safety Code §§ 119400-119402

CMP Pharma is committed to compliance with applicable regulations and authorities in the promotion, distribution and marketing of its products. In order to achieve these goals, CMP Pharma has implemented a Comprehensive Compliance Program (CCP) consistent with Cal. Health & Safety Code § § 119400-119402, based on its good faith understanding of the statutory requirements.

As recommended in the OIG Guidance, CMP Pharma’s CCP has been tailored to the unique characteristics and needs of the Company. While the OIG Guidance recognizes that even an effective compliance program may not completely eliminate all misconduct by individuals, CMP Pharma’s CCP is designed to prevent and detect violations. CMP Pharma’s expectation is that all employees will adhere to company policies with regard to Federal and state regulations and will implement disciplinary and corrective actions when misconduct is identified.

In accordance with California requirements, CMP Pharma has established an annual spending limit of two thousand dollars ($2,000) per California licensed Health Care Professional (HCP) and intends to monitor employee activities to ensure compliance. Additionally, CMP Pharma’s CCP is available to individuals who request it by contacting [email protected] or 1-800-227-6637.

CMP Pharma’s CCP includes annual audits and assessments for purposes of this declaration. This declaration is being made on 15 August 2024 for calendar year 2024.