KDL Nutrition is committed to conducting its business ethically and in accordance with all applicable laws and regulations. To the best of its knowledge and based upon a good faith understanding of the applicable statutory requirements, KDL Nutrition is in compliance, in all materials respects.

KDL Nutrition has adopted a comprehensive compliance program to implement internal controls and procedures that promote adherence to applicable statutes, regulations and requirements of the federal healthcare programs and to provide specific guidance to employees. Our compliance program is based on the requirements of applicable federal and state laws and the recommendations set forth in the “Compliance Program Guidance for Pharmaceutical Manufacturers” which was developed by the United States Department of Health and Human Services Office of Inspector General. As a manufacturer of medical devices, our Compliance Program was developed taking into consideration applicable compliance guidance as well as relevant requirements and best practices set forth in the “Advanced Medical Technology Association (AdvMed) Code of Ethics for Interactions with Healthcare Professionals” and various codes and guidance issued by other healthcare professional associations, industry organizations, and KDL Nutrition’s customers. Therefore,KDL Nutrition determined that it was more appropriate for the company instead to adopt policies and procedures consistent with The AdvaMed Code of Ethics on Interactions with Healthcare Professionals (“AdvaMed Code”).