Corporate Responsibility

Adapt Pharma, Inc. (“Adapt Pharma”) has developed a Corporate Compliance Program based on the components in the Office of Inspector General’s Compliance Program Guidance for Pharmaceutical Manufacturers (“OIG Guidance”), and is a basis for compliance with standards of corporate conduct. The Corporate Compliance Program is designed to promote compliance with applicable laws and regulations; the Pharmaceutical Research and Manufacturers of America Code on Interactions with Healthcare Professionals (“PhRMA Code”); and other rules and requirements applicable to our business. The primary components of our Corporate Compliance Program are as follows:

Corporate Compliance Program Compliance Officer and Compliance Committee

Adapt Pharma has a Chief Ethics and Compliance Officer as well as and Ethic and Compliance Committee who are responsible for implementing, operating and monitoring the Corporate Compliance Program. Legal and regulatory assistance are provided as needed.

Standards of Business Conduct

Adapt Pharma’s Standards of Business Conduct contains the ethical and compliance principles that guide our business operations, based on the expectation that management, employees, and agents of Adapt Pharma act in compliance with laws, regulations and company policies and procedures. They include policies, procedures and other guidelines that address compliance risk areas, including areas identified in the OIG Guidance and PhRMA Code.

Training and Education

Adapt Pharma provides education and training to employees on a variety of compliance-related topics, in order to communicate and explain our standards, policies, procedures and guidelines to our employees. Training programs are regularly revised and additional areas of training are added as needed.

Communication

Adapt Pharma is committed to promoting communication between management and employees. To that end, Adapt Pharma has developed a confidential telephone number available to all employees, vendors, customers, contractors and the public for the purpose of asking questions or reporting concerns. The number is 844-4ADAPT1 (844-423-2781). Adapt Pharma also encourages employees to address questions or concerns to their manager, Human Resources, the Legal Affairs Department or the Compliance Department.

Auditing and Monitoring

Adapt Pharma reviews and assesses business activities for compliance with applicable laws, regulations, guidelines, and company policies and procedures. Corrective action plans are developed to address concerns identified through these reviews.

Disciplinary Guidelines

Adapt Pharma takes disciplinary action as needed in response to violations of applicable laws, regulations, guidelines and company policies and procedures. Disciplinary action may include warnings, suspension, termination and/or other sanctions.

Corrective Action

Adapt Pharma responds appropriately to address issues that are identified or reported. Appropriate corrective action may be taken, including disciplinary action, training, and improvement of policies and procedures.

Revisions to Standards

Our Corporate Compliance Program is dynamic, to ensure that the Corporate Compliance Program is always suitable to meet changing compliance standards.