Corporate Responsibility

California Declaration

ADAPT PHARMA maintains a Comprehensive Compliance Program that is designed to comply with all applicable state and federal laws and regulations, including the Office of Inspector General’s 2003 Guidance, Compliance Program Guidance for Pharmaceutical Manufacturers, and the 2002 (rev. 2009) Pharmaceutical Research and Manufacturers of America (PhRMA) Code on Interactions with Health Care Professionals, concerning the marketing and promotion of our products. To our knowledge, as of the date of this declaration, ADAPT PHARMA is, in all material respects, in compliance with California Health & Safety Code §§ 119400-119402.

To comply with the California Statute, Adapt Pharma has established a maximum annual aggregate dollar limit of two thousand dollars ($2,000) for gifts, promotional materials, and related activities provided to California healthcare professionals. This limit is an annual limit, not an average or targeted spending limit. The amount spent per healthcare professional is therefore anticipated to be less than this maximum amount. Per the Statute, this annual spending limit does not include the value of, among other things: (1) drug samples provided to physicians and healthcare professionals intended for free distribution to patients; (2) financial support of independent education including continuing medical education; (3) financial support for health education scholarships; and (4) payments made for legitimate professional services provided by a healthcare professional so long as the amount paid is based up the fair market value of the services provided.

[7/29/16]: Pursuant to Cal. Health and Safety Code §119400 et seq., Adapt Pharma Inc., hereby certifies in this annual declaration, that to our knowledge, and based on our good faith understanding of the statutory requirements it is in compliance with the provisions of Cal. Health and Safety Code §119402. This includes the requirement that it has adopted, and is in compliance with, a Comprehensive Compliance Program which is in accordance with the Office of Inspector General’s (OIG) 2003 Guidance, Compliance Program Guidance for Pharmaceutical Manufacturers, and the Pharmaceutical Research and Manufacturers of America (PhRMA) 2002 (rev. 2009) Code on Interactions with Health Care Professionals.

A copy of Adapt Pharma’s Compliance Program and declaration is available by calling this toll-free number: 844-4ADAPT1 (844-423-2781)