Compliance & Ethics

Compliance Program Description
Declaration Clause for California
Code of Business Ethics
Support of PhRMA Code

Compliance Program Description

I. Introduction

Purdue Pharma L.P. and certain of its independent associated U.S. companies (Purdue) are committed to establishing and maintaining an effective compliance program in accordance with the "Compliance Program Guidance for Pharmaceutical Manufacturers," published by the Office of Inspector General, U.S. Department of Health and Human Services (the "HHS-OIG Guidance"). Our Ethics and Compliance Program is a key component of our commitment to the highest standards of corporate conduct.

The purpose of our Ethics and Compliance Program is two-fold: to prevent, detect, and remediate violations of law, regulations, or company policies, and to promote an ethical culture within the organization. It is Purdue's expectation that employees will comply with our Code of Business Ethics and the policies established in support of such Code, as well as our Healthcare Law Compliance Policies. As the HHS-OIG Guidance recognizes, however, the implementation of such a program cannot guarantee that improper employee conduct will be entirely eliminated. In the event that Purdue 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.

Purdue has described below the fundamental elements of its Corporate Compliance Program. As HHS-OIG calls for in its Guidance, we have tailored our Compliance Program to fit the unique environment of our company. Moreover, our Compliance Program is dynamic; we regularly review and enhance our Compliance Program to meet our evolving compliance needs.

II. Overview of Compliance Program

1. Leadership and Structure.
   • Vice President, Corporate Compliance. We have selected Bert Weinstein as our Vice President, Corporate Compliance, to serve as the primary contact for compliance activities. We will ensure that Mr. Weinstein has the ability to exercise independent judgment and effectuate change within the organization as needed. Mr. Weinstein has the responsibility of developing, operating, and monitoring the Compliance Program. He reports to the President and Chief Executive officer of Purdue, is a member of Purdue's Executive Committee, and has direct access to the Board of Directors.
   • Compliance Committees. Purdue has established Compliance Committees and functions with the Sales & Marketing, Research & Development, Technical Operations, and Administration departments to advise the Vice President, Corporate Compliance and assist in the implementation of the Compliance Program. These Compliance Committees meet regularly to identify and manage areas of risk and areas of critical focus for our Company.
2. Written Standards.
   • Purdue's Code of Business Ethics is our statement of ethical and compliance principles guiding our daily operations. The Code establishes our expectation that management, employees, and agents of the company act in accordance with all law, regulations, and company policies. The Code articulates our fundamental principles and values, providing a framework for action within our organization.
   • The HHS-OIG Guidance has identified several potential risk areas for pharmaceutical manufacturers, and has called on companies to develop compliance policies in these areas. These risk areas are: (1) data integrity pertaining to government reimbursement policies, (2) kickbacks and other illegal remuneration, and (3) compliance with laws regulating drug samples. Purdue has published Healthcare Law Compliance Policies to help address these risks and train our employees to act in accordance with these policies.
   • We have established annual spending limits for certain promotional activities directed toward healthcare professionals who prescribe or may influence prescribing in California. At the present time our annual spending limit is $750.00. Examples of items that fall within this spending limit are: infrequent, modest, in-service breakfasts and/or lunches for healthcare providers and their staff; infrequent, modest dinners in connection with product specific and non-product educational programs; items of use to healthcare professional in his/her practice or to his/her patients; and reprints of journal articles and related information. This amount does not include cash payments or honoraria paid to healthcare professionals pursuant to contracts for bona fide consulting or other services. Purdue Pharma L.P. does not and will not provide any item of value to any healthcare provider with the intent of influencing that healthcare provider’s prescribing habits.
3. Education and Training. A critical element of our Compliance Program is the education and training of our employees on their legal and ethical obligations under applicable federal healthcare programs. Purdue will effectively communicate our standards and procedures and regularly review and update our training programs.
4. Internal Lines of Communication. Purdue actively fosters dialogue between management and employees. Our goal is that all employees should know whom to turn to when seeking answers to questions or reporting possible code violations, and should be able to do so without fear of retribution. To that end, we have adopted open-door policies, as well as confidentiality and non-retaliation policies. We have a confidential, toll-free Purdue Ethics and Compliance Hotline (1-877-PURDUE1) through which employees and persons outside of our company may report any concerns or suspected violations of law, regulation, or company policy.
5. Auditing and Monitoring. Purdue's Ethics and Compliance Program includes efforts to monitor, audit, and evaluate adherence to the company�s compliance policies and procedures. We note that, in accordance with the HHS-OIG Guidance, the nature, extent, and frequency of our compliance monitoring and auditing may vary according to new regulatory requirements, changes in business practices, and other considerations.
6. Responding to Potential Violations. Purdue's Ethics and Compliance Program sets forth clear, disciplinary consequences of violating the law or company policy. While each situation will be considered on a case-by-case basis, we will utilize disciplinary action to address inappropriate conduct and deter future violations.
7. Corrective Action Procedures. A compliance program increases the likelihood of identifying and preventing unlawful and unethical behavior. However, HHS-OIG recognizes that even an effective compliance program may not prevent all violations. As such, our Ethics and Compliance Program requires the company to respond promptly to potential violations of law, regulation, or company policy. Then we can assess whether the violation is due to gaps in our policies, practices, or internal controls, take appropriate disciplinary action, and work to prevent future violations.

Declaration Clause for California, as of July 1, 2011

Purdue Pharma L.P. hereby declares that to the best of our knowledge, and based on our good faith understanding of the statutory requirements, we have established a Comprehensive Compliance Program (CCP) compliant with the requirements of California Health and Safety Code §§ 119400-119402. The owners, management, and employees of Purdue Pharma L.P. are committed to conducting our business according to the highest ethical standards. While we cannot completely eliminate the possibility that an individual employee will violate these standards, our program is reasonably designed to detect and prevent violations of state and federal laws as well as our own internal policies and procedures. As of July 1, 2005, the above-referenced compliance program was in place, and we are continually reassessing our compliance program to improve it.