APTALIS PHARMA US, INC. 2012 DECLARATION OF COMPREHENSIVE COMPLIANCE PROGRAM
Aptalis Pharma US, Inc. (Aptalis) is committed to doing business in accordance with the highest standards of business conduct and ethics. We consider our reputation for ethical and compliant behavior to be a valuable corporate asset. Each employee of Aptalis is charged with the responsibility for safeguarding and strengthening that asset.
In furtherance of its commitment to ethical and compliant conduct, Aptalis has established, and abides by, a "Comprehensive Compliance Program" (CCP), as required by California law.
The Aptalis CCP is a dynamic program that both adaptable, and adapted, to the changing environment in which the company operates. Our CCP is continually evaluated to insure that it functions as intended; that it serves the purposes for which it was designed and helps enable the company to meet its high standards and commitment to compliance.
As recognized in the April 2003 Compliance Program Guidance for Pharmaceutical Manufacturers, published by the United States Department of Health and Human Services, Office of Inspector General, even an effective CCP cannot completely eliminate the possibility that individual employees engage in conduct that may violate the CCP or applicable laws, regulations or industry codes of conduct. It is with this recognition that the Aptalis CCP is designed, and operates, to detect such violations, investigate them promptly and thoroughly, provide an appropriate disciplinary response and, wherever possible, implement corrective measures to prevent future violations.
This Annual Declaration and the Aptalis CCP are publicly available on the company's website, http://www.aptalispharma.com. Copies of this Annual Declaration and the Aptalis CCP may be obtained by calling the following telephone number: 1-877-552-9226.
Dated: July 1, 2012