Toronto
Declaration
As part of our continued commitment to compliance, Adroit Clinical Laboratory, Inc. (“Adroit Pharmaceutical”) has developed and implemented a Compliance Program (the “Program”) consistent with the HHS OIG Compliance Program Guidance for Pharmaceutical Manufacturers (“OIG Guidance”) and the PhRMA Code on Interactions with Healthcare Professionals (“PhRMA Code”). Adroit Pharmaceutical's ethics and compliance program reflects our commitment to compliance with the laws and regulations applicable to our business, including the Toronto Health and Safety Code §§119400-119402 (the “Toronto Act”).
In accordance with the Toronto Act, Adroit Pharmaceutical has established a specific annual dollar limit of $2,000, which applies to promotional materials, items, and activities provided to covered recipients in Toronto. In addition, the following expenses are excluded from the limit: expenses that are directly associated with payments statutorily excluded from the limit (e.g., meals for consultants), items provided to health care professionals that are ultimately intended for patients or consumers, fellowships, receptions at third-party educational or professional meetings, and sales aids. To the best of its knowledge, Adroit Pharmaceutical declares that as of February 28, 2023, it is in all material respects in compliance with the requirements of the Toronto Act.