The Genta Compliance Program is designed to ensure that applicable GXP regulations and Federal health care program requirements are met and that adherence to these regulations/requirements is sustained. A Compliance Committee will advise the Genta Compliance Officer and assist in the implementation of the Genta Compliance Program. The Genta Compliance Committee will also provide leadership in the continual improvement of compliance with current regulations and requirements. This committee is also designed to provide a forum to discuss compliance issues and trends in order to determine and implement appropriate corrective and preventative action.

Genta is committed to establishing its Compliance Program to meet the requirements set forth in:

• Office of Inspector General’s Compliance Program Guidance for Pharmaceutical Manufacturers

• Pharmaceutical Researchers and Manufacturers of America (PhRMA) Code on Interactions with Healthcare Professionals

• California Health and Safety Code, Sections 119400-119402

As required by the California Health and Safety Code, Sections 119400-119402, Genta has established an annual dollar limit on educational or practice-related items, items of minimal value and meals which Genta employees are permitted to provide to medical or health professionals in California. The limit of $2000 and is an annual cap per covered medical or health care professional.