CORPORATE VALUES

NS Pharma is fully committed that all of our activities comply with all applicable laws and regulations. Our internal performance requirements are based on high ethical standards to meet the expectation of all our stakeholders.

This Code of Conduct outlines key elements of our corporate policies. Combined with our policies and procedures, this Code of Conduct aims to help our colleagues think through the issues and make the right decisions.

CODE OF CONDUCT

Code of Conduct

ETHICSPOINT HOTLINE

Every person, regardless of position, shares in the responsibility for promoting a positive environment, with open lines of communication throughout the company. NS Pharma has a phone and a web-based reporting system, which are managed by NAVEX Global’s EthicsPoint system, to enhance communication and empower you to promote safety, security, and ethical behavior.

This system allows you to communicate your concerns or suggestions and enables you to remain anonymous, if you so choose. We have partnered with NAVEX Global to manage the reporting system and maintain confidentiality.

Input is essential to ensuring that NS Pharma maintains a positive, productive workplace. The EthicsPoint system, may be used to anonymously report something that may be cause for concern. Reports will be reviewed and addressed in compliance with applicable laws and regulations.

NO RETALIATION POLICY

NS Pharma has a policy prohibiting retaliation and to protect employees who make good faith reports of potential violations of laws, regulations or NS Pharma policy.

No Retaliation Policy

NS PHARMA CALIFORNIA COMPLIANCE DECLARATION

California Health & Safety Code, Sections 119400 – 119402, (“California Compliance Law”) requires pharmaceutical companies to adopt a compliance program in accordance with the April 2003 publication “Compliance Program Guidance for Pharmaceutical Manufacturers” (“OIG Compliance Guidance”) developed by the United States Department of Health and Human Services Office of Inspector General (“OIG”) and policies for compliance with the Pharmaceutical Research and Manufacturers of America (“PhRMA”) “Code on Interactions with Health Care Professionals” (“PhRMA Code”) within six months of any update or revision of the PhRMA Code. Revisions to the July 1, 2002 PhRMA Code were effective January 2009.

The NS Pharma Compliance Program includes numerous policies and procedures and is continually assessed and evaluated to ensure consistency with additional laws and guidance. It is designed to prevent, detect and remediate violations of law, regulations and company policies, as well as to promote an ethical culture that will, among other things, guide our interactions with healthcare professionals and healthcare entities. In the event that NS Pharma becomes aware of any potential or actual violations of policy or law, an investigation will be triggered and, if necessary, followed by appropriate remedial or corrective actions in accordance with the NS Pharma Compliance Program.

As part of the Compliance Program, NS Pharma has established a specific annual aggregate dollar limit of $2,000 on gifts, items or activities NS Pharma may give or otherwise provide to an individual medical or healthcare professional in California on an annual basis. This limit may be revised from time to time by NS Pharma in its sole discretion, in which case the revised limit will be published in this section of the NS Pharma website within a reasonable period of time following revision. This limit represents an expenditure cap and not a goal or an average expenditure amount. NS Pharma has established an internal monitoring system designed to help ensure compliance with the annual spending limits in California.

The annual limits do not include the following:

NS Pharma is committed to conducting its business ethically and in compliance with all applicable laws. To the best of its knowledge and based on a good faith understanding of the statutory requirements, the Company has established a Compliance Program that meets the requirements set forth in California Health & Safety Code, Sections 119400-119402. The Company has tailored its Compliance Program to meet the specific needs of the Company and continuously assesses the effectiveness of the Compliance Program. The Company has established an internal monitoring system designed to help ensure compliance with its respective annual spending limits in California and is working to establish additional corporate tracking and monitoring processes. Thus, subject to the limitations described above, NS Pharma declares that, based upon current tracking and monitoring systems, the Company is in material compliance with its Compliance Program, its good faith understanding of the requirements of the California Compliance Law, and its established annual spending limits for the current time period. NS Pharma will assess its Compliance Program at least annually and the Compliance Program was last assessed in August 2020.

As recognized by the OIG Compliance Guidance, even an effective compliance program cannot eliminate the possibility that one or more individual employees engage in conduct that would be considered improper. Accordingly, this declaration is not intended and should not be construed to imply that the Company has not identified any individual instances in which an employee has or may have violated one or more provisions of its Compliance Program. In such situations, the Company takes reasonable and appropriate remedial or corrective action in a manner consistent with its Compliance Program.