H. D. Smith is committed to the highest standards of ethical conduct and corporate compliance. Based on our good-faith understanding and to the best of our knowledge, we have established a Code of Business Conduct and Ethics that is reasonably designed to prevent and detect violations of our Standards of Conduct and applicable laws and regulations. Our Code of Business Conduct is tailored to the size, organizational structure, operational activities and resources of H. D. Smith to meet compliance goals consistent with our corporate ethics and with the statutory requirements of Cal. Health and Safety Code SSSS119400-119402 and all other pertinent regulations in states in which H. D. Smith operates distribution facilities. H. D. Smith's Code of Business Conduct 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. To the best of our knowledge, we are in material compliance with the Code of Business Conduct and Ethics as described, meaning that we have established the elements outlined and have set up procedures to implement the policy's requirements. This declaration is made as of January 1, 2016. A written copy of this declaration of our Code of Business Conduct may be obtained by calling 888.467.7979.