Stiefel has established an effective
Corporate Compliance Program ("Program") in accordance with the April 2003
"Compliance Program Guidance for Pharmaceutical Manufacturers," published by
the Office of Inspector General, U.S. Department of Health and Human Services.
The Stiefel Corporate
Compliance program includes:
·
The appointment of a dedicated Global Compliance Officer
·
Oversight by Stiefel's Executive Leadership through a Compliance
Committee
·
Documented compliance policies and procedures
·
Regular and effective compliance education and training
·
Open lines of communication, including a toll-free number for anonymous
reports
·
Monitoring and auditing activities to evaluate compliance with the
Stiefel Program
·
Procedures for responding to identified problems and implementing
corrective action
To the best of our knowledge and based
upon our good faith understanding of the statutory requirements, Stiefel has
established a comprehensive compliance program in accordance with the
requirements of California Health and Safety Code §§119400 - 199402 and
complies with the Program in all material respects. Additional
information regarding the Compliance Program and this declaration can be
obtained by contacting the Compliance Office at 1-770-945-0101.