As required by California Law, NeuroTherm has implemented a Comprehensive Compliance Program in accordance with the Office of Inspector General of the Department of Health and Human Services April 2003 Compliance Program Guidance for Pharmaceutical Manufacturers (“OIG Guidelines”). This Comprehensive Compliance Program includes policies for compliance with the Advanced Medical Technology Association's (or AdvaMed's) Code of Ethics On Interactions with Health Care Professionals published July 1, 2009. As a key part of the Comprehensive Compliance Program, NeuroTherm has implemented numerous standard operating procedures and corporate policies on marketing practices and interactions with healthcare professionals, including an annual dollar spending limit of $1,500 per individual healthcare professional. The Company has trained and continues to train employees on these policies on a regular basis. A Compliance Committee, chaired by a Chief Compliance Officer, has been established to guide and foster communication with employees, to monitor employee compliance with Company policies, and to take corrective and/or disciplinary action when necessary. NeuroTherm has strictly adhered to its Comprehensive Compliance Program and will update the Program as necessary to reflect any revisions to either the OIG Guidelines or the AdvaMed Code. Any interested party can call toll-free 888-655-3500 to request a printed copy of this declaration or further information regarding NeuroTherm’s Compliance Program.