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California Annual Declaration of Compliance

Drug Marketing Practices Act §§ 119400-02

Cook has adopted a comprehensive compliance program (CCP), organized around our Code of Conduct, which is based on guidance established by the US Department of Health and Human Services-Office of Inspector General (DHHS-OIG); the Medical Device Manufacturers Association Guidelines for Interaction with Customers; guidance from AdvaMed; and the PhRMA Code to the extent that code is instructive to medical device manufacturers.

Cook has a CCP designed to effectively prevent, detect and correct non-compliance with our company policies and the laws and regulations which apply to our business activities while encouraging and fostering an ethical corporate culture.

Cook sales and marketing professionals are trained in appropriate interaction with healthcare professionals. It is the policy of Cook companies not to exceed an annual limit of two thousand and five hundred dollars ($2,500) per medical or health professional licensed in California for promotion.

To request an explanation of Cook’s comprehensive compliance program, you may call toll-free 800.457.4500 to leave a message or send a written request to Cook Group Incorporated, Attention: Ethic & Compliance Program, PO Box 1608, Bloomington, Indiana, 47402, USA.