Tenpoint Therapeutics™ as of May 1, 2026, affirms its compliance with the Comprehensive Compliance Program (CCP) and California Health and Safety Code §§ 119400-119402. The CCP, further detailed below, incorporates the essential elements of an effective compliance program as outlined in the “Compliance Program Guidance for Pharmaceutical Manufacturers” published by the Office of the Inspector General, U.S. Department of Health and Human Services (HHS-OIG Guidance). Additionally, Tenpoint Therapeutics™ has adopted the “Code on Interactions with Healthcare Professionals” from The Pharmaceutical Research and Manufacturers of America (PhRMA Code), and has developed policies, procedures, and processes to ensure adherence to the PhRMA Code.
Tenpoint Therapeutics™ is dedicated to conducting business in line with the highest ethical and compliance standards. Central to this commitment is the establishment and ongoing maintenance of a CCP consistent with HHS-OIG Guidance. Employees are expected to comply with the CCP, and any potential violations of the CCP, applicable laws, regulations, industry codes, or company policies are thoroughly investigated and resolved. When appropriate, disciplinary measures—including termination—are taken, and corrective actions are implemented to prevent future violations.
The CCP is designed to be adaptable, evolving with the company’s growth and changes in legal, regulatory, or industry obligations. Regular reevaluation ensures continued improvement and effectiveness. The fundamental components of the CCP are outlined below.
Compliance training is routinely provided to all Tenpoint Therapeutics™ employees, including during new hire orientation. Training covers the CCP, company policies, and all relevant laws, regulations, and industry codes.
The company uses various internal communication tools to address compliance topics with employees. These include an intranet site for the Compliance Department and a regularly distributed newsletter. Tenpoint Therapeutics™ responds to individual compliance questions, addresses issues at company meetings, and maintains ongoing compliance communications. Employees are instructed to report actual or potential compliance violations and are provided resources, such as an independent, third-party operated Compliance Hotline, to anonymously report compliance matters if desired.
Annual compliance risk assessments, routine monitoring, and audits are conducted by Tenpoint Therapeutics™. Reports from these activities are shared with the Vice President, Head of Compliance, the Compliance Committee, and senior management. Identified issues and opportunities for improvement are addressed, with education, training, and corrective actions implemented as needed.
The CCP mandates prompt responses to potential violations of law, regulation, industry codes, or company policies. Each potential violation is investigated and evaluated individually. When appropriate, disciplinary action—including termination—is taken.
Upon investigation of reported or detected compliance issues, the company assesses whether additional corrective actions are warranted. This assessment includes determining whether any gaps exist in policies, training, or internal controls. If a gap is identified, corrective action is taken to address it.
