Comprehensive Compliance Program

Graceway Pharmaceuticals, LLC is committed to the highest standards of corporate citizenship and ethical conduct, and Graceway continually strives to create a corporate culture that embodies these values in every aspect of its business.Accordingly, Graceway has established a Comprehensive Compliance Program andMarketing Code of Conduct (the “Compliance Program”) structured around the seven elements outlined in theApril 2003 “Compliance Program Guidance for PharmaceuticalManufacturers,” published by the United States Department of Health and Human Services, Office of Inspector General (“OIG Guidance”), as well as various applicable state and local laws.

Graceway’s Compliance Program is designed to prevent and detect violations of ethical norms, legal requirements, and company policy.While the implementation of any program of this type cannot guarantee that improper employee conduct will be eliminated in its entirety, Graceway expects that its employees will comply with its Compliance Program. In the event that Graceway becomes aware of violations of law or company policy, we will investigate the matter and, where appropriate, take disciplinary action and implement corrective measures to prevent future violations.