Cranial Technologies, Inc.

Annual Compliance Declaration (January 24, 2023)

California Health and Safety Code § 119400-119402

California Declaration of Compliance

Cranial Technologies, Inc. (“Cranial”) is committed to complying with all applicable laws, regulations, and industry standards. Towards this end, Cranial has developed a Comprehensive Compliance Program in accordance with pharmaceutical industry compliance program guidance published by the U.S. Department of Health and Human Services Office of Inspector General (“OIG”). Cranial’s Compliance Program includes Standards of Conduct and policies and procedures that all Cranial employees, officers, and directors are required to follow. Cranial regularly reviews and updates its Compliance Program to ensure consistency with any new laws or guidance. The Compliance Program is designed to prevent, detect and remediate violations of law, regulations and company policies, as well as to promote an ethical culture that will guide Cranial’s interactions with healthcare professionals and entities. Based on a good faith understanding of the requirements of Section 119402 of the California Health and Safety Code, Cranial declares that, to the best of its knowledge, its Comprehensive Compliance Program addresses the California statutory requirements for inclusion of policies addressing the OIG’s guidance, the PhRMA Code and limits on gifts and incentives to healthcare professionals. Cranial also declares that it is, in all material respects, in compliance with its Comprehensive Compliance Program as of January 24, 2023. A copy of Cranial’s Comprehensive Compliance Program is available here, or by calling 866-403-6361.

Natalie Kehm,

Chief Compliance Officer

Corporate Social Responsibility Coordinator



COM001 Rev14 ECO21-017 Effective Date: 01/25/2021