COMPLIANCE AND ETHICS

In pursuit of our Mission and Vision, US WorldMeds is committed to embracing a culture that values honesty, creativity, action, integrity in relationships, a passion for success, and good stewardship of Company resources. We will endeavor to develop, recognize, reward, and retain teammates who deliver results and embody our Mission and Vision. We expect the best from our people, and our drive for excellence begins and ends with a commitment to ethical conduct and compliance with law.

US WorldMeds operates in a highly complex, rapidly changing, and heavily regulated environment, and compliance with all applicable laws and regulations is US WorldMeds' expectation. Our commitment as individuals to standards that are ethical and fair provides the basis for dealing with various constituents including the public, our customers, and each other.

To meet these expectations, US WorldMeds has developed and implemented a comprehensive Compliance Program in adherence to government guidance on effective compliance programs.

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Comprehensive Compliance Program

The primary purpose of the US WorldMeds Compliance Program, and that of its affiliated companies, is to communicate and deploy the standards of ethical conduct and to help detect and prevent violations of applicable laws or company policy. The Compliance Program is based on the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services’ (i) Compliance Program Guidance for Pharmaceutical Manufacturers and (ii) General Compliance Program Guidance, and addresses the specific risk areas identified therein, as well as others identified by the Compliance Officer. However, as the OIG Guidance explicitly recognizes, the implementation of a Compliance Program cannot guarantee the outright mitigation of risks associated with noncompliance with applicable healthcare law and regulation. Nonetheless, it is our expectation that its employees are to adhere to US WorldMeds’ Compliance Program.

While US WorldMeds is not a member of the Pharmaceutical and Research Manufacturers of America ("PhRMA"), US WorldMeds has adopted and adheres to the tenets of the PhRMA Code on Interactions with Healthcare Professionals in the jurisdictions in which the code has been codified by state law. All of US WorldMeds' personnel are expected to adhere to the corporate Code of Conduct, the PhRMA Code in states where it is required, and all other applicable industry codes and compliance policies.

US WorldMeds has tailored its Compliance Program to fit its unique environment and size. The program is assessed and adjusted regularly to ensure it is responsive to the Company's evolving business and associated compliance risks.

Compliance Officer

US WorldMeds' Compliance Officer is charged with overseeing its Compliance Program. The Compliance Officer has direct access to both the Chief Executive Officer and Board of Directors and is charged with developing the standards of conduct issued as part of the Compliance Program, directing auditing and monitoring activities, as appropriate, and implementing corrective measures, as necessary.

Code of Conduct

The US WorldMeds Code of Conduct ("Code") contains principles and standards to guide our business behavior. Irrespective of any other changes in our business, US WorldMeds commits to practice the highest standards of business conduct. The Code of Conduct is intended to assist in the fulfillment of our commitment to integrity and to act as the basic guide to our program of compliance with the laws under which we operate.

Concerns or questions about violations of laws, rules, regulations, or the Code should be directed to our compliance hotline, 855-247-7800, or if employed by US WorldMeds you may contact our Manager, Human Resources.

Policies and Procedures

In addition to the Code of Conduct, US WorldMeds has developed and implemented Standard Operating Procedures (SOPs) and internal controls to ensure responsible conduct.

US WorldMeds provides effective compliance training for all employees on all elements of the Compliance Program, including SOPs, as well as on applicable laws and regulations. In addition, the Company will conduct internal auditing and monitoring to evaluate compliance with company standards and all applicable laws and regulations.

Transparency and Responding to Poterntial Violations

It is expected that employees will report any compliance-related concerns. As such, a non-retaliation policy is in effect at US WorldMeds. Employees may report their concerns anonymously, or directly to the Compliance Officer, any manager, or the Human Resources Department.

In the event that US WorldMeds becomes aware of a violation of law, regulation, or company policy, US WorldMeds is committed to investigating the matter and where appropriate, taking disciplinary action, and implementing corrective measures to prevent further such violations.

Resources and Disclosures

Annual California Spending Limit (PDF)
California Health & Safety Code Section 119402 - Declaration of Compliance (PDF)
Federal Financial Conflict of Interest Policy (PDF)
Payments to Physicians (PDF)

USWM, LLC

Michael Brown, Associate General Counsel & Compliance Officer

July 1, 2024
To obtain a copy of this written declaration please email [email protected] or call toll-free, 1-855-247-7800.