ExEm Foam Inc.

California Comprehensive Compliance Program

ExEm Foam Inc. is committed to establishing and maintaining an effective compliance program in accordance with the Compliance Program Guidance published by the U.S. Department of Health and Human Services, Office of Inspector General1(the “OIG Guidance”). Further, the healthcare industry has established and ExEm Foam Inc.’s Comprehensive Compliance Program is designed in accordance with, the PhRMA Code on Interactions with Health Care Professionals (PhRMA)2. In accordance with the voluntary standards established by the OIG Guidance and as explicitly recognized in the OIG Guidance, we have tailored our Compliance Program to fit the unique environment and size of ExEm Foam Inc. We regularly review our Compliance Program to meet the evolving industry guidance and our company’s compliance needs.

‍

Our Compliance Program established by our Board of Directors is designed to prevent and detect violations of law or ExEm Foam Inc.’s policies; however, as recognized by the OIG Guidance, the implementation of a Compliance Program cannot guarantee that improper conduct will be entirely eliminated. It is ExEm Foam Inc.’s expectation that employees and our representatives will comply with our HCP Interactions Policy and the other policies established in support of our Compliance Program. In the event that ExEm Foam Inc. becomes aware of potential violations of law or company policy, the company will investigate the matter and take relevant disciplinary action and implement corrective measures to prevent future violations.

‍

As required by the California Health & Safety Code §119402(d) ExEm Foam Inc. has implemented an annual spending limit of $2,000 on educational items, promotional items or activities that ExEm Foam Inc. may provide to licensed California healthcare professionals. These promotional items and activities are also subject to restrictions set forth in our HCP Interactions Policy (consistent with the PhRMA Code) and other Compliance Program policies and procedures.

Company, Inc. 2021 Declaration of Compliance

ExEm Foam Inc. hereby declares that to the best of its present knowledge and belief, it is in compliance with its Comprehensive Compliance Program and the relevant requirements of California Health & Safety Code §§119400-119402.

Contact Information

For a copy of this Declaration or for more information regarding our Compliance Program, please contact ExEm Foam Inc. by sending an e-mail to compliance@exem-foam.com

1 Compliance Program Guidance for Pharmaceutical Manufacturers.