Galderma
     Verified-Accredited Wholesale Distributor

Compliance Program

Galderma Laboratories, L.P. is committed to conducting our business in an ethical and legal manner.

To ensure compliance with the laws, industry guidelines, and Galderma standards applicable to the marketing and sale of our products, the Company established a Compliance Program that is consistent with the Department of Health and Human Services Office of Inspector General Guidance. Our Compliance Program takes into consideration the nature of our business, whether it be pharmaceuticals or consumer products, and is one of the key components of our commitment to the highest standards of conduct.

The Galderma Compliance Program, along with Galderma’s Code of Ethics, the U.S. Compliance Code of Conduct and other related policies, summarizes the ethical and legal standards to which all Galderma employees must adhere. Our Compliance Program is dynamic; we regularly review and enhance our Compliance Program to meet our evolving compliance needs. The purpose of our Compliance Program is to prevent and detect violations of law or company policy. As HHS-OIG calls for in its Guidance, we have tailored our Compliance Program to fit the unique environment of our Company. The Company has designated a Compliance Officer with responsibility for developing, operating and monitoring this program. The Compliance Officer makes periodic reports to Compliance Committee and has the authority to report significant issues directly to the General Counsel and the President of the Company.

The Company provides a toll-free telephone line to report suspected violations of Company policies or laws. Calls can be made anonymously and without fear of retribution 24 hours a day, seven days a week. Allegations of non-compliance are documented and investigated so that appropriate corrective action can be taken when warranted.

Comprehensive Compliance Program

California

Vermont

California Transparency in Supply Chains Act of 2010