Corporate Compliance

STATE OF CALIFORNIA

COMPREHENSIVE COMPLIANCE PROGRAM DECLARATION
Pursuant to California Health & Safety Code ss. 119400-119402
October 27, 2011

URL Pharma has developed a Comprehensive Compliance Program (“CCP”) that is compliant with the requirements of the California Marketing Practices Act (California Health and Safety Code §§ 119400-119402), the HHS-OIG Compliance Program Guidance for Pharmaceutical Manufacturers, and the PhRMA Code on Interactions with Healthcare Professionals. URL Pharma’s CCP is tailored to the size, organizational structure, and resources of the company, and is reasonably designed to prevent and detect compliance violations in accordance with the HHS-OIG Compliance Program Guidance for Pharmaceutical Manufacturers. To the best of our knowledge, URL Pharma is in compliance with its CCP and the requirements of the California Health and Safety Code §§ 119400-119402 as of this date. URL Pharma will continually evaluate and update its CCP as necessary and appropriate on an ongoing basis. URL Pharma is committed to upholding the highest standards of business conduct and ethics in its relationships with customers, employees, shareholders, the business community, and state and federal governments.

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Copies of this Declaration and a description of our Comprehensive Compliance Program may be obtained by calling 1-(888)-309-1553 or clicking here.