Pharmacyclics’ ethics and compliance program (the “Program”) reflects our commitment to compliance with the laws and regulations applicable to our business, including the California Health and Safety Code §§119400-119402 (the “California Act”). Interested parties may view the Program online or may also call 1-800-254-0462 for a copy of any of the Program materials.

In accordance with the California Act, Pharmacyclics has established a specific annual dollar limit of $2,500, which applies to promotional materials, items, and activities provided by an employee of Pharmacyclics businesses to covered recipients in California. In addition, the following expenses are excluded from the limit: expenses of a de minimis value (i.e., with a value of $10 or less), 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, Pharmacyclics declares that as of March 31, 2021, it is in all material respects in compliance with our Program and the requirements of the California Act.