DFINE, Inc. is committed to establishing and maintaining an effective Compliance Program in accordance with “Compliance Program Guidance for Pharmaceutical Manufacturers,” published by the Office of Inspector General, U.S. Department of Health and Human Services (the “HHS-OIG Guidance”). Our Compliance Program is one of the key components of our commitment to the highest standards of conduct.


The purpose of our Compliance Program is to prevent and detect violations of law or company policies. As the HHS-OIG Guidance recognizes, however, the implementation of such a program cannot guarantee that improper conduct will be entirely eliminated. Nonetheless, it is our expectation that employees and others working on DFINE’s behalf will comply with our Code of Conduct, and the policies established in support of the Code. In the event that we become aware of potential violations of law or Company policy, we will investigate and, where appropriate, take disciplinary action and implement corrective measures to prevent future violations. Described below are the fundamental elements of the DFINE, Inc. Compliance Program. Consistent with the HHS-OIG Guidance, we have tailored our program to fit the unique environment of our Company. We regularly review and enhance our program to meet our evolving compliance needs.

Compliance Program Structure

The core principles of our Compliance Program are set forth in our Code of Conduct. The Company from time to time adopts additional policies and procedures to ensure compliance with these core principles. These policies include specific policies governing our interactions with Health Care Professionals. The Company has also adopted and is committed to compliance with the AdvaMed Code of Ethics on Interactions with Health Care Professionals.

In accordance with California Health & Safety Code § 119402(d), the Company has implemented an annual spending limit of $1500 on gifts and promotional items and activities that the Company may provide to licensed California health care professionals. Our interactions with licensed health care professionals are subject to further restrictions set forth in our Code of Conduct, the AdvaMed Code of Ethics and other applicable policies and procedures.

2014/2015 Annual Written Declaration of Compliance with the DFINE, Inc. Comprehensive Compliance Program

As required by the California Health & Safety Code §119402(e), DFINE, Inc. hereby declares that, to the best of its knowledge, it is in all material respects in compliance with its Comprehensive Compliance Program and the relevant requirements of California Health & Safety Code §§ 119400-119402.

DFINE, Inc. July 1, 2014

Further Information

For a copy of this Declaration or for more information, please contact Linda Lechner, DFINE’s Corporate Compliance Officer, by calling (408) 770-1111 or by sending an email to ComplianceOfficer@dfineinc.com. DFINE also has a toll-free number for reporting potential violations of law or company policy. That number is (888) 662-3897.