Summary of YalePharma Policies on Business Conduct

The Summary of YalePharma Policies on Business Conduct (the YL Book) is YalePharma’s guide to Company policies and legal requirements that govern how we conduct business around the world. This booklet is a general reference for all employees everywhere we do business. It does not describe all applicable laws or Company policies, or give full details on any individual law or policy. You can find information about and summaries of relevant law, all Company policies and procedures, and much more compliance information on the Compliance web site, http://compliance.YalePharma.com At any time, you may also contact the Corporate Compliance Group directly with your questions or concerns.

YalePharma reserves the right to modify, revise, or alter any policy, procedure, or condition related to employment at its sole discretion and at any time without notice and without revision of the Summary of YalePharma Policies on Business Conduct (the YL Book). The contents of the YL Book do not constitute the terms of a contract of employment, and nothing contained herein should be construed as a guarantee of continued employment — employment at Yalepharma is on an at-will basis. The YL Book is not a legal document and is intended for informational use only. The information herein supersedes previous printed YL Books, can be changed or revoked unilaterally by the Company at any time, and is not all-inclusive. The online version of the YL Book, accessible through the Compliance web site, supersedes all printed versions, including this YL Book. If any information in the YL Book, whether in print or online, differs from established YalePharma policies or procedures, the legal policy and procedure documents govern.

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