Effective January 1, 2008, the business of Bayer Pharmaceuticals Corporation was merged into Bayer HealthCare Pharmaceuticals Inc., and ceased its corporate existence. Bayer HealthCare Pharmaceuticals Inc. is the name formally adopted by Berlex, Inc. as of April 4, 2007. In this posting, the term “Legacy Bayer” will refer to Bayer Pharmaceuticals Corporation (including Bayer’s Biological Products business). The term “Legacy Berlex” refers to Berlex, Inc. its affiliate Intendis, Inc. and Bayer HealthCare Pharmaceuticals Inc. prior to January 1, 2008. The term Bayer refers to Bayer HealthCare Pharmaceuticals Inc. subsequent to January 1, 2008.

In compliance with California Health and Safety Code sections 119400 and 119402, and consistent with the Department of Health and Human Services, Office of Inspector General’s Compliance Program Guidance for Pharmaceutical Manufacturers (April 2003) and the PhRMA Code on Interactions with Healthcare Professionals (July 1, 2002), Bayer has adopted the following Comprehensive Compliance Program (“CCP”).

The policies published here on our website are not new to Bayer, Legacy Bayer and Legacy Berlex, but are being made public in accordance with the requirements specified in California law. The laws governing Bayer and other pharmaceutical companies are not limited to California, but are enforceable by federal and state criminal, civil and administrative penalties. Violations may result in jail sentences, large fines, or exclusion from Federal and State programs including Medicare, Medicaid and Department of Defense.

Our program is reasonably designed to prevent improper conduct from occurring. Bayer expects employees to comply with its Comprehensive Compliance Program, but is not asserting that in all circumstances it can prevent individual employees from engaging in conduct that deviates from Bayer’s policies. Bayer will make a good faith effort to enforce the program, prevent violations, and address any inappropriate conduct that may occur.

Bayer provides relevant employees with training to assist them in meeting the responsibility of conducting Company business in an ethical manner. Each employee is required to certify that he/she has completed this training program. The publication of our policies is not intended to alter the employment-at-will relationship in any way.

All Bayer employees have a responsibility to comply with all legal requirements and must report suspected violations of our compliance programs and related policies to their supervisors, the Law and Patents Department, or the Compliance Officer through the Confidential Disclosure Program. Reports to the Confidential Disclosure Program may be made anonymously. Any employee who reports a suspected violation, or raises any compliance matter, will not be subject to any retaliation or adverse action based upon such reports.

Bayer, Legacy Bayer and Legacy Berlex declare that on or before July 1, 2005 they have adopted a CCP applicable to California medical or health professionals pursuant to California Health and Safety Code sections 119400 and 119402. To the best of its knowledge and based upon a good faith understanding of the applicable statutory requirements, Bayer is not aware of any violations between January 1, 2007 – December 31, 2007 of its Comprehensive Compliance Program or of California Health and Safety Code §§ 119400-119402 relating to California medical or health professionals that have not been addressed and for which corrective action has not been taken. Copies of this declaration and the CCP may be obtained by calling 1-877-256-3562 (our toll-free number).

June 6, 2008

Click the following link to view the Comprehensive Compliance Program

Click the following link to view the Code of Conduct