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California Health and Safety Code §§119400-119402 Annual Declaration of Compliance July 1, 2007 COOK has adopted a comprehensive compliance program (CCP), organized by our Code of Conduct, based on guidance for pharmaceutical companies established by the US Department of Health and Human Services-Office of Inspector General (DHHS-OIG), guidance from the Pharmaceutical Research and Manufacturers of America (PhRMA), to the extent it applies to medical device manufacturers, and the guidance for all corporations from the US Federal Sentencing Commission. As a privately held medical device manufacturer, COOK has freely accepted the challenge of embracing the guidance from both government and industry primarily intended for the pharmaceutical industry believing that to be in the best interest of good medicine and patient safety. COOK has a CCP designed to effectively prevent, detect and correct non-compliance with our company policies and the laws and regulations which apply to our business activities while encouraging and fostering an ethical corporate culture. COOK sales and marketing professionals are trained in appropriate interaction with health care professionals as provided in the guidance from the DHHS-OIG and PhRMA. It is the policy of COOK companies that promotional items will not exceed an annual average of Four Hundred Dollars per medical or healthcare professional. To request a paper copy of COOK's comprehensive compliance program you may call toll-free (800) 468-1379 extension 8889 to leave a message or send a written request to Cook Group Incorporated, Attention: Compliance Program, PO Box 1608, Bloomington, Indiana, 47402, USA.
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