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Comprehensive Corporate Compliance Program Description

MEDRAD has developed and disseminated written compliance standards, and procedures that guide the conduct of its employees and the day-to-day operations of MEDRAD and its subsidiaries. These standards are continuously reassessed, revised and supplemented as appropriate.

MEDRAD has designated a Chief Compliance Officer who reports to the Company’s CEO and to its Board of Directors regularly on compliance issues, and MEDRAD has established a compliance committee to assist in continued implementation of its compliance program.

MEDRAD continues to develop and implement regular, effective education and training programs for all relevant employees.

MEDRAD has created and maintains an effective line of communication with its employees including the availability of a compliance telephone hotline for its employees to report complaints or ask questions. The compliance hotline is available 24 hours a day, 7 days a week. Calls to the compliance hotline cannot be traced and the system affords callers the opportunity to remain anonymous.

MEDRAD utilizes audits and other risk evaluations techniques to monitor compliance, identify problem areas and assist in the reduction of any identified problems.

MEDRAD has a corporate policy and procedures in place to address the non-employment or retention of individuals or entities excluded from participation in federal health care programs, and a mechanism for the enforcement of appropriate disciplinary action against employees or contractors who have violated the company policies and procedures.

MEDRAD has implemented policies and procedures for the investigation of identified instances of non-compliance or misconduct, including policies to address the prompt and proper response to detected offenses. These Corrective Action policies and procedures are continuously reassessed, revised or supplemented as appropriate.

MEDRAD’s Comprehensive Compliance Program recognizes that compliance is dynamic. It provides for revisions when necessary to reflect changes in company operations, the AdvaMed Code of Ethics, the Compliance Program Guidance for Pharmaceutical Manufacturers published by the Office of Inspector General for the U.S. Department of Health and Human Services and applicable laws.

To obtain a copy of the above, please call 1-800-814-2858.

Declaration

MEDRAD declares substantial compliance with California Health and Safety Code.

Employee Complaint Procedure

MEDRAD's parent company, Schering AG, Germany, has instituted Employee Complaint Procedures for Accounting and Auditing Matters, which are complementary and consistent with MEDRAD’s procedures.

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