Smart Health India is committed to high standards of ethical conduct and corporate compliance. To that end, we have established a Comprehensive Compliance Program composed of the Smart Health India Standards of Business Conduct, as well as supplemental internal policies and procedures that address the statutory requirements of Cal. Health and Safety Code §§119400-119402 (the "California Law") to the extent applicable to its business. If there is any ambiguity or inconsistency as between the Standards of Business Conduct and these policies and procedures, the policies and procedures will control and be deemed to be the operative sections of the Comprehensive Compliance Program with respect to the provisions at issue.
The Comprehensive Compliance Program recognizes that compliance is dynamic. It provides for revisions when necessary to reflect changes in company operations and applicable laws.
As of July 1, 2019, to our knowledge, we are in material compliance with the Comprehensive Compliance Program and the California Law as described above. Smart Health India established $2,000 as the annual spending limit for gifts, promotional materials, or items or activities that Smart Health India may provide to the identified individuals under, and as required by, the California Law. The Comprehensive Compliance Program, including the annual spending limit, is subject to ongoing review and accordingly, may be updated from time to time.
To obtain a written copy of this Summary and our Standards of Business Conduct, you may call the Ethics and Compliance department at 614.757.7504.