Par Health’s Public Policy Engagement 

Par Health’s public policy engagement focuses on building a constructive discourse in the political and regulatory environment to further the Company’s interests and values, and to enhance its ability to meet patient needs. For this reason, the Company actively engages in dialog with policymakers to explain and advocate its perspectives. Par Health’s political and lobbying activities (including contributions made by the Par Health Political Action Committee (the “Par Health PAC”) take place without regard to the personal preferences or affiliations of team members, officers, directors, customers or vendors. Par Health’s public policy initiatives are subject to robust oversight, designed to comply with applicable law(s) and exclusively consider the Company’s interests, including trade, healthcare, patient access, regulatory, litigation, intellectual property, competition and other issues directly impacting Par Health. Par Health’s Code of Conduct outlines the process for team members who engage with government officials on behalf of Par Health to influence official action. 

Par Health supports the right of all team members to participate in individual political activity. Team members must engage in such activity on their own time, at their own expense and in accordance with applicable law(s). Team members must also communicate that they are acting independently and not as a Par Health representative. 

Par Health’s Board of Directors is apprised of political and lobbying policies, procedures and key initiatives. 

In accordance with applicable law, Par Health exclusively makes political contributions from the Par Health PAC, a nonpartisan organization that provides opportunities for team members to participate in the American political process. The Par Health PAC makes contributions to candidates and office holders at both the federal and state level and discloses its contributions to the Federal Election Commission (on Form LD-2) and appropriate state authorities. Contributions by team members to the Par Health PAC are entirely voluntary. Par Health will neither favor nor disfavor team members based on such contributions.  

Par Health has established a Comprehensive Compliance Program (CCP) for its U.S. based operating companies that complies with the “Compliance Program Guidance for Pharmaceutical Manufacturers” (“CIG Compliance Guidance”) developed by the U.S. Department of Health and Human Services Office of Inspector General and policies for compliance with the Pharmaceutical Research and Manufacturers of America (“PhRMA”) “Code on Interactions with Health Care Professionals” (PhRMA Code”). 

As part of our CCP, Par Health has established a specific annual aggregate dollar limit of $2,000 on gifts, promotional materials, or items or activities that Par Health may give or otherwise provide to an individual medical or healthcare professional in California on an annual basis (from January 1 to December 31). Such items or activities primarily include: 

These items and activities are primarily directed to the dissemination or communication of medical and scientific information as a resource for healthcare professionals to assist in making clinical or other medical judgments. This limit may be revised from time to time, in which case the revised limit will be published in this section of the company website. This limit represents a spending cap, not a goal or average; in many cases, the amount spent per prescriber is substantially less than the cap amount. 

In accordance with California Health and Safety Code §§ 119400-119402, the annual limits do not include the following: 

People throughout the world count on our products every day to help them lead healthier lives, and at Par Health, Inc., we believe that all human life should be held in the highest regard. Par Health is a member of the Pharmaceutical Supply Chain Initiative (PSCI), a consortium of pharmaceutical and healthcare companies that share a vision of better social, environmental and economic outcomes within the supply chain (https://pscinitiative.org/home).  

Par Health also supports the human rights of workers and the treatment of all people with dignity and respect through two core policy documents: the Par Health Code of Conduct and the Par Health Supplier Code of Conduct.  

Par Health requires all of its managers and employees to be trained on the Code of Conduct and to certify annually both their understanding and compliance. The Code of Conduct reflects Par Health’s aims for good global citizenship and worldwide social responsibility. It provides that our business units must provide clean and safe working environments and conditions, forbid child labor or compulsory labor at their facilities, and require that employees receive all benefits mandated by applicable law. It further states our policy that business units must not engage in activities that fail to protect individual dignity and respect, even if permissible under local law.  

The Par Health Supplier Code of Conduct outlines the expectations for the ethical behavior of our suppliers, and prohibits child and compulsory labor, human trafficking and slavery, unsafe and hazardous working conditions and environments, and any behavior that does not maintain human dignity and respect. These standards apply to all suppliers of goods and services to any Par Health business or supplier, regardless of location. We expect these standards to apply both to supplier operations as well as supplier sourcing of materials.  

Although Par Health does not have a formal process for verifying its supply chains or obtaining certification of compliance from suppliers, all suppliers are subject to audit. Par Health conducts audits of its suppliers based on an internal assessment of business and environmental health and safety risk. Par Health does not use a third party to verify supply chains or perform unannounced audits.  

Par Health encourages reporting of any unethical conduct up through supervisors and the leadership chain of command, or through the Par Health Integrity Hotline. The Integrity Hotline is a simple way for employees, suppliers and customers to express concerns regarding any potential unethical situation. The Integrity Hotline is available seven days a week, 24 hours a day. Additional information may be found at ParHealth.ethicspoint.com. 

Par Health maintains internal accountability standards and procedures for employees and suppliers and may take disciplinary action against anyone found to have violated the Par Health Code of Conduct or the Part Health Supplier Code of Conduct, which can include termination of employment or supply agreements. 

Par Health Cybersecurity: Vulnerability Reporting 

Par Health is committed to delivering safe and secure products and services.  When cybersecurity vulnerabilities are discovered, we work diligently to resolve them. This document describes Par Health’s assurance for receiving reports related to potential cybersecurity vulnerabilities.    
 
How to Contact Us 
If you have identified a potential security vulnerability with one of our services or websites, contact Par Health by sending an email to cybersecurity@parhealth.com.  Include "VULNERABILITY DISCLOSURE" in the subject line.  After your incident report is received, the appropriate personnel will contact you to follow up.  To ensure confidentiality, we encourage you to encrypt any sensitive information you send to us via email. 

Information to Include 
To help us triage and prioritize submissions, a report detailing your security research should include, at a minimum, the following: 

Our Responsibilities 
Par Health strives to acknowledge receipt of all submitted reports within five business days.