Pharma Intelligence's Biomedtracker Research and Analyst Conduct Policies and Procedures

1. Introduction - Description of Biomedtracker
2. Ownership
3. Policy Regarding Third Party Influence
4. Policy Regarding Conflicts of Interest
5. Policy Regarding Material Non-Public Information
6. Policy Regarding Distribution of BMT Information

Introduction - Description of Biomedtracker

Biomedtracker ("BMT") is an independent database and research service that tracks and analyzes developmental drugs through the FDA approval process. The information contained in BMT is obtained exclusively from publicly available sources such as company press releases, medical conference presentations, public company SEC filings, company web site materials and company slide presentations.

Although BMT does NOT provide buy or sell recommendations on any stocks, it does provide opinions on the percentage likelihood of approval of certain developmental drugs. These likelihood of approval estimates are based on two elements: 1. the objective likelihood of approval based on average historical approval results of drugs in a particular regulatory phase and 2. a subjective opinion by BMT's senior analysts (the "Senior Analysts") based on clinical trial data released publicly on and prior to the date of such opinion.

This document serves as Pharma Intelligence UK Limited's written policies regarding its Biomedtracker product and covers such topics as Ownership, Conflicts of Interest, Third Party Influence, Material Non-Public Information and Distribution of Research.

Ownership

1. Pharma Intelligence UK Limited is NOT a broker/dealer or investment banking firm and is NOT related to or affiliated with any broker/dealer or investment banking firm.

No Third Party Influence

1. BMT's drug and company opinion is produced entirely by the Senior Analysts. NO third party, including public biotech or pharmaceutical companies, sell-side investment banking firms, buy-side investment firms, or other research providers has any influence on the content, conclusions, or timing of any of the reports or analysis produced by BMT.
2. As a courtesy we will, from time to time, facilitate discussions between our Senior Analyst team and our paid subscribers, custom clients, or trial members regarding companies, drugs, or indications that we cover. While opinions may be shared and debated during those discussions, all the final conclusions in BMT's research are produced by our Senior Analysts.
3. All of BMT's research is presented to subscribing clients and qualified trial members at the same time via e-mail notifications and via posting on the BMT website.

Policy Regarding Conflicts of Interest

1. Pharma Intelligence UK Limited is paid a fixed annual fee by its subscribing clients for access to BMT (including all of the historical data and research contained therein and all of the new research and data produced during the term of the subscription period). For that reason, BMT provides its clients with data, information and analysis that it feels is valuable, interesting and relevant to those clients.
2. Neither Pharma Intelligence UK Limited, BMT, nor any of its affiliated entities provide any investment banking services or provide any securities trading services.

Policy Regarding Material Non-Public Information

1. BMT only reports on information from publicly available sources such as company press releases, medical conference presentations, public company SEC filings, individual inquiries to company investor relations, company web sites and slide presentations.
2. If any employee or independent contractor of BMT obtains information which they believe may be material, non-public information, whether from a client or other source, that person has agreed to provide such information to Pharma Intelligence UK Limited's general counsel to determine whether it can be disseminated. Such employee or independent contractor has also agreed not to trade in any security when they are in possession of any such material, non-public information.
3. The Key Opinion Leader Insight add-on service to BMT ("KOL Insight") contains opinions on developmental and marketed drugs from anonymous medical experts around the globe. Only BMT subscribers who pay for this service or who are on trial for this service receive access to these opinions. The publications are presented as interviews or 5-10 question physician surveys.
4. The Key Opinion Leader Insight add-on service to BMT ("KOL") contains opinions on developmental drugs from anonymous medical experts around the globe. Only BMT subscribers who pay for this service or who are on trial for this service receive access to these opinions. The experts who provide the opinions contained in the KOL Service have agreed to NOT provide any material non-public information in any interviews that they may be privy to. Their opinions are their own any may differ, sometimes substantially, from the opinion of the Senior Analysts.
   1. Experts are identified through a third-party vendor who has a strict policy ensuring adherence to compliance standards and best practices. All experts are further anonymized in KOL Insight publications, and have agreed to NOT provide any material non-public information in any interviews or surveys that they may be privy to. Their opinions are their own and may differ, sometimes substantially, from the opinion of the Senior Analysts.
   2. Prior to publication on BMT, all interviews and physician surveys are reviewed and transcribed by the Senior Analysts. Any material non-public information disclosed by an expert is deleted from the publication.

Policy Regarding Distribution of BMT Information

1. Pharma Intelligence UK Limited does provide free access to its site to members of the media on a select basis. Those journalists may quote or reference BMT's data, research, or opinions on drugs in their respective publications.
2. Except for subscribing and custom data clients, qualified prospective subscribers, select journalists, and employees of Pharma Intelligence, no one has access to the BMT website, BMT custom data or receives our research in any other format.
3. Redistribution of our research by our clients or qualified trial members to anyone is strictly prohibited and violates our terms of usage.

For additional questions regarding our policies, please contact Client Services.