California Annual Spending Limit

Based on our good faith efforts and understanding of the statutory requirements set forth by the State of California, DEY^® developed an annual spending limit to fit the size, organizational structure, and resources of our company. Accordingly, it is DEY's policy that an annual spending limit for any support (i.e., gifts or meals) given to a healthcare provider in California not exceed a $500 annual limit.

Examples of gift and/or meals are as follows:

Lunch-and-learns or business meal expenses;
Patient-related gifts provided to healthcare professionals.

The following forms of items or activities are excluded from the annual spending limit:

Promotional items such as pens or notepads, which are valued at less than $15;
Detail pieces and reprints;
Samples;
CME support;
Educational Grants; and
Fee-for-Service agreements (consultants, speakers, etc.).

July 1, 2008

Pursuant to Cal. Health and Safety Code § 119400 et seq., DEY hereby certifies that it is in compliance with the provisions of Cal. Health and Safety Code § 119402, including the requirement that it has adopted, and is in compliance with, a Comprehensive Compliance Program that it believes to be in accordance with the Office of Inspector General's Compliance Guidance for Pharmaceutical Manufacturers and the Code on Interactions with Healthcare Professionals issued by the Pharmaceutical Research and Manufacturers of America (PhRMA) on or about July 1, 2002.