Declaration Under Cal. Health & Safety Code § § 119400-119402

Ther-Rx is committed to producing high quality products and providing high quality services in full compliance with all applicable requirements and authorities, and an effective Compliance Program will help achieve these goals. To the best of our knowledge and based on our good faith understanding of the statutory requirements, we have developed a Comprehensive Compliance Program (“CCP”) consistent with Cal. Health & Safety Code § § 119400-119402, and we are in compliance with this CCP and the requirements of the California Statute.

As recommended in the OIG Guidance, our CCP has been tailored to the unique characteristics and needs of the Company. While the OIG Guidance recognizes that even an effective compliance program may not completely eliminate all misconduct by individuals, our CCP is designed to prevent and detect violations. Our expectation is that all employees will adhere to legal requirements and Company policies, and we will implement disciplinary and corrective actions when misconduct is identified.

The Company encourages individuals to report actual or suspected wrongdoing or violations of laws, rules, regulations, Company ethical standards, or any other irregularities. A Compliance Hotline, which is available at all times by calling 1-800-679-0187, is established for compliance reporting purposes. The Hotline is operated by an independent, external service provider (completely separate from Ther-Rx), to offer the caller continuous access and complete confidentiality and anonymity, consistent with the Company’s Compliance Plan.

This declaration is made as of July 1, 2011. Our compliance program is dynamic, and in order to address evolving compliance needs we will assess our Compliance Program regularly, and at least annually for purposes of this declaration.

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