Commitment to Compliance

At PharmaNest, we believe that a culture of compliance leads to better business and medical outcomes for our Company and patients, respectively.

As part of our commitment, all employees are expected to adhere to the values and standards established in the Code as well as in the Company’s policies and applicable procedures.

We have implemented a comprehensive compliance program to ensure our operations and activities are always conducted with integrity. Our compliance program is composed of the following elements to support its effectiveness:

• Compliance officers: The Company maintains Compliance Officers charged with providing broad leadership and strategy for how the Company integrates compliance requirements within its everyday business activities

• Ethics and compliance committees: The Company uses respective bodies, such as Ethics and Compliance Committee(s), composed of cross-functional senior leadership, to both promote and provide oversight over the Company’s compliance initiatives.

• Code, policies and procedures: The Company sets standards for acceptable employee behaviors and interactions with other employees, customers and business partners.

• Communications and training: The Company regularly communicates with and trains employees on the Company’s policies and applicable procedures to enable them to effectively do their jobs consistent with compliance requirements

• Monitoring and auditing: The Company regularly reviews its business activities to identify potential risks and instances of non-compliance.

• Corrective actions: The Company swiftly and consistently takes action to uphold compliance requirements, regardless of the identity of the affected employees.

While a comprehensive compliance program serves a critical role in supporting our Company’s efforts, only the day-to-day action and commitment of our employees will result in its effectiveness.