National Resilience, LLC

Last Revised on March 4, 2024

At Resilience, we are committed to upholding the highest standards of Corporate Compliance. Our dedication to integrity, ethics, and regulatory adherence is paramount. We operate with accountability, ensuring that every aspect of our business aligns with applicable laws and industry regulations. By fostering a culture of compliance, we aim to build trust among our stakeholders, safeguard our reputation, and contribute to a sustainable and responsible business environment. Explore this section to learn more about our commitment to Corporate Compliance and the principles that guide our practices.

Corporate Compliance Plan

Our Corporate Compliance Plan assists Resilience with detecting and preventing potential violations of laws, regulations, Codes of Practice, and customer obligations related to Corporate Compliance. Our Plan also supports Resilience by establishing relevant and informative Corporate Policies, Standard Operating Procedures, and Trainings related to Corporate Compliance topics.

Corporate Compliance Governance

Corporate Compliance Governance is critical to establishing an effective Corporate Compliance Program. Our governance approach aligns with the seven (7) elements of an effective Corporate Compliance Program, as described by the U.S. Office of Inspector General ("OIG"). Resilience has implemented governance capabilities, such as assigning a Corporate Compliance Officer, and an Executive Committee that meets with the Resilience Senior Leadership Team and Board of Directors (or Committees thereof) to discuss Corporate Compliance topics.

Global Code of Business Conduct and Ethics

Resilience has developed a comprehensive Global Code of Business Conduct and Ethics (the “Code”), applicable to every member of our team. It is mandatory for all directors, officers, employees, and third-party personnel (i.e., contractors, contingent workers, and consultants) to adhere to the Code, along with other pertinent policies relevant to their respective roles and activities.

SB 1765 Declaration

California law SB 1765, codified at California Business and Professions Code, Sections 119400 to 119402 (“the California law”), requires all pharmaceutical (manufacturing) and medical device companies to adopt a Corporate Compliance Plan based upon the OIG Guidance and the PhRMA Code. Under the California law, a pharmaceutical manufacturing company must also annually declare that it is in compliance with its own Corporate Compliance Plan and the requirements of the Sections 119400 to 119402. A pharmaceutical manufacturing company must make its Corporate Compliance Plan and its annual declaration of compliance available to the public on its website and through a toll-free number at 1-888-737-2460. We understand the California statute only imposes these obligations for activities directed to citizens of California.

Resilience declares that to the best of our knowledge and based on a good faith understanding of the California statute, as of January 2024, Resilience is in compliance with the Corporate Compliance Plan described above. The Corporate Compliance Plan is intended to be a dynamic program to meet the Company’s evolving compliance needs and expectations. Therefore, Resilience will continue to develop and refine its Corporate Compliance Plan.

Annual Spending Limit

The California law requires pharmaceutical manufacturing companies to adopt a specific annual dollar limit on gifts, promotional materials, or items or activities that the pharmaceutical manufacturing company and its employees and representatives may give or otherwise provide to an individual medical or healthcare professional in California. The limit does not include amounts attributable to financial support for continuing medical education or payment for legitimate professional services.

Resilience has adopted an annual spending limit of $3,000.00. This limit is neither an average spending limit, nor a targeted spending limit, and Resilience believes that its actual spending will be less than this limit. Resilience reserves the right to revise its annual limit from time to time.