Partner Therapeutics’ Healthcare Compliance Program

Partner Therapeutics Inc. (“PTx” or the “Company”) is committed to essential principles of good corporate conduct and integrity in all of its activities. To that end, PTx has established and will maintain an effective Compliance Program to support the acquisition, development, and commercialization of medically important pharmaceutical products.

The key components of the Compliance Program address each of the seven elements of an effective compliance program as outlined in the Compliance Program Guidance for Pharmaceutical Manufacturers issued in 2003 by the Office of the Inspector General of the Department of Health and Human Services (“OIG Guidance”), as well as consideration of the Pharmaceutical Research and Manufacturers of America Code on Interactions with Health Professionals as updated and made effective January 2009 (PhRMA Code), the Prescription Drug Marketing Act, relevant guidelines of the American Medical Association (AMA), the guidelines for the Accreditation Council for Continuing Medical Education (ACCME), and other guidance put issued by the US Food and Drug Administration (FDA) and other government agencies.

As the OIG Guidance envisions, PTx has designed its Compliance Program to fit the size, resources, market position, and other unique aspects of our Company. PTx also recognizes that an effective compliance program must evolve and respond to the changing circumstances of the Company and the compliance, legal and regulatory environment. PTx is committed to continuous quality improvement based on regular review, assessment, and development of the Compliance Program.

For more information on compliance at PTx, please send an email to compliance@partnertx.com.

The following is information on specific state ethics and reporting regulations that may affect marketing, sales and other activities at Partner Therapeutics, Inc. In accordance with state laws, Partner Therapeutics, Inc. is disclosing this information in the form required.

California Compliance Declaration

Wholesale Acquisition Cost Information for Colorado Prescribers

Wholesale Acquisition Cost Information for Connecticut Prescribing Practitioners and Pharmacists