CALIFORNIA COMPLIANCE LAW DECLARATION

As part of Ceterix Orthopaedics continuing commitment to corporate compliance, Ceterix Orthopaedics declares that, to the best of its knowledge, and based on a good faith understanding of the statutory requirements of California Health and Safety Code § 119400 and 119402, it has adopted a Comprehensive Compliance Program as mandated by this California law. To the best of our knowledge, as of March 7, 2017, Ceterix Orthopaedics believes that it is in compliance with its Comprehensive Compliance Program and its good faith understanding of the requirements of California Health and Safety Code § 119400 and 119402.

Ceterix Orthopaedics has established written policies and procedures to ensure compliance with the AdvaMed Code of Ethics including the Ceterix Orthopaedics Comprehensive Compliance Program and other complimentary policies that outline the company’s commitment to compliance and corporate accountability. The standards set forth in the policies apply to all Ceterix Orthopaedics employees, contractors and agents, and adherence to company policies is a condition of employment. Ceterix Orthopaedics does not permit gifts, promotional materials, items, or activities prohibited by the AdvaMed Code, HHS-OIG Guidance, or FDA regulations. For items and activities that are not prohibited, Ceterix Orthopaedics has set a cumulative annual spending limit of $1,500 per California healthcare professional. We track and monitor compliance with this spending limit to the best of our ability and will modify our internal processes as necessary.

For questions about our Comprehensive Compliance Program or to obtain a copy, please contact us at compliance@ceterix.com