PharmaEssentia USA Corporation (“PharmaEssentia U.S.”) strives for the highest standards of corporate conduct and is committed to establishing and maintaining an effective healthcare compliance program (“Compliance Program”). Our Compliance Program addresses matters covered by the U.S. Department of Health and Human Services (“HHS”) Office of Inspector General “Compliance Program Guidance for Pharmaceutical Manufacturers” (“OIG Guidance”) and the PhRMA Code on Interactions with Healthcare Professionals  (“PhRMA Code”).

In accordance with Chapter 8, Part 15, Division 104 of the California Health and Safety Code (§§ 119400-119402), PharmaEssentia U.S. has established an annual aggregate dollar limit of $2,000 per healthcare professional licensed in California for the following items: 1) meals provided in connection with informational presentations or scientific exchange; 2) educational items to enhance patient care (excluding items of minimal monetary value and/or of no independent value such as printed advertising, reimbursement fact sheets), and items for the benefit of and distribution to patients and their caregivers.

PharmaEssentia U.S. requires its employees to comply with its Employee Handbook, which serves as the ethical code of conduct, as well as its Compliance Policy Book, and other guidance related to gifts, promotional materials, and items provided to healthcare professionals. PharmaEssentia U.S.  is committed to training its employees and to monitoring in order to prevent and detect violations. In the event PharmaEssentia U.S. becomes aware of potential violations of law or company policy, it will, where appropriate, take reasonable steps to investigate the matter, pursue disciplinary action, and/or implement corrective measures to prevent future violations. To the best of its knowledge and based on a good faith understanding of the statutory requirements, PharmaEssentia U.S. has established a Compliance Program that meets the requirements set forth in California Health & Safety Code, Sections 119400-119402 and that it is in material compliance with its comprehensive compliance program.

If you would like to receive a printed version of this declaration and/or documentation of PharmaEssentia U.S.’s compliance program, you may contact PharmaEssentia U.S. at Ethics_Reporting@pharmaessentia.com or the anonymous complaint line at 1-833-706-0058. If you call the anonymous complaint line, please state that you are requesting a printed copy of PharmaEssentia U.S.  California declaration of compliance and/or documentation of its comprehensive compliance program.