Summary of California Compliance Program
Cardinal Health is committed to high standards of ethical conduct and corporate compliance. To that end, we have established a Comprehensive Compliance Program composed of the attached Standards of Business Conduct as well as supplemental internal policies and procedures that address, and provide for implementation of, the statutory requirements of Cal. Health and Safety Code §§119400-119402 (the "California Law".) If there is any ambiguity or inconsistency as between the Standards of Business Conduct and these policies and procedures, the policies and procedures will control and be deemed to be the operative sections of the Comprehensive Compliance Program with respect to the provisions at issue.Cardinal Health's Comprehensive Compliance Program recognizes that compliance is dynamic. It provides for revisions when necessary to reflect changes in company operations, the Compliance Program Guidance for Pharmaceutical Manufacturers published by the Office of Inspector General for the U.S. Department of Health and Human Services, the PhRMA Code on Interactions with Health Professionals, and applicable laws.
As of July 1, 2008, to our knowledge, we are in material compliance with the Comprehensive Compliance Program as described above. Cardinal Health establishes $1500 as the annual spending limit for all (a) gifts, (b) meals, and (c) promotional items and activities Cardinal Health may provide to the identified individuals under, and as required by, the California Law. The Comprehensive Compliance Program, including the annual spending limit, is subject to ongoing review and accordingly, may be updated from time to time.
To obtain a written copy of this Summary and our Standards of Business Conduct, you may call the Ethics and Compliance department at 1.800.234.8701.
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