Corporate Compliance

A Message from our CEO

Dear Colleague,

In keeping with our commitment in maintaining the highest level of integrity and ethical responsibility, we have developed the Medicure Corporate Compliance Program. Conducting our business within the boundaries of this Program will ensure the successes we realize are accomplished honestly, fairly, and with the utmost respect for healthcare providers, patients, and fellow employees.

The Program contains fundamental legal, regulatory, and ethical guidelines for conducting business at Medicure and its US subsidiary, Medicure Pharma. It summarizes our compliance infrastructure and policies and serves as a valuable resource for employees or others with compliance questions or concerns.

A culture of compliance cannot be realized without the commitment and recognition by each employee of their role in fulfilling our compliance mission. With your help, we can achieve our business objectives while maintaining our integrity and enhancing our reputation as an ethical leader in the pharmaceutical industry.

Albert Friesen, Ph.D.
CEO, Medicure Inc.

Mission Statement

The Medicure Corporate Compliance Program has been designed to ensure that Medicure and its subsidiaries conduct business with the highest level of awareness, training, commitment, and adherence to applicable laws and regulations. To do so requires the implementation of policies and procedures that address potential compliance risk areas as well as identifiable mechanisms for reporting, investigating, monitoring, and correcting cases of suspected non-compliance.

The Medicure Corporate Compliance Program has been developed in accordance with the requirements and guidelines set forth in the Department of Health and Human Services (DHHS), Office of Inspector General (OIG) Compliance Guidance.

Compliance Organization

Medicure has developed a compliance infrastructure designed to ensure accountability for legal and ethical responsibilities across the Company. The compliance infrastructure is comprised of the Chief Compliance Officer,

I. Chief Compliance Officer

The Chief Compliance Officer has primary responsibility for oversight of the Corporate Compliance Program.

II. Compliance Officer

The Compliance Officer is responsible for implementing the Compliance Program according to the direction of the Chief Compliance Officer. The Compliance Officer may enlist support from internal or external resources to assist him/her with the implementation of the Program. The Compliance Officer provides periodic compliance updates to the Chief Compliance Officer, President & CEO. The President & CEO will provide compliance updates to the Board of Directors annually and may request information from the Compliance Officer in order to do so. Other responsibilities of the Compliance Officer include:

• Making periodic revisions to the Corporate Compliance Program in light of any regulatory, legal, or organizational changes requiring such revisions
• Coordinating and ensuring employees undergo the essential compliance training
• Developing open communication channels to encourage employees to inquire about or report compliance issues without fear of retribution
• Overseeing internal investigations and any corresponding corrective actions
• Directing monitoring and auditing efforts to ensure compliance with laws, regulations and policies; and
• Completing the necessary periodic declarations or certifications relative to applicable compliance requirements

Policies and Procedures

It is the responsibility of the Compliance Officer, under the direction of the President and Chief Compliance Officer, to create, revise, and communicate policies and procedures that address areas of potential compliance risk within the Company. These policies shall be reviewed periodically and updated as necessary to reflect regulatory, legal or organizational changes. These policy reviews, as well as the requisite training and education, either initially or as updated, shall be performed by the Compliance Officer in conjunction with the manager of the affected department within the organization.

The Company has adopted core compliance policies that provide the prevailing principles to help ensure that we conduct our business affairs with honesty and integrity and in full compliance with all applicable laws, rules and regulations.

In addition, all employees are required to familiarize themselves with and adhere to all Company standards, policies and procedures that apply in the areas within the scope of their work responsibilities.

Compliance Training and Education

An effective education and training program is an integral part of the Corporate Compliance Program. Employees will be required to participate in compliance-related training designated by the Compliance Officer, or by another function or discipline within the organization. Our compliance education and training programs are designed with the following objectives:

• To educate employees on their ethical and legal obligations in reference to applicable federal health care program requirements
• To encourage a culture of compliance within the organization and ensure that employees understand their role in the compliance process
• To promote knowledge of and compliance with corporate policies and procedures and relevant federal, state, and local laws and regulations
• To communicate industry standards and governmental requirements while providing a means for the quick identification and resolution of compliance issues
• To understand the consequences of failing to comply with the presented comprehensive compliance program
• In addition, the Company regularly reviews and updates the training program where new updates are needed, as well as identifying additional areas that need to be addressed

Internal Compliance Questions and Concerns

Situations which involve concerns about conflicts of interest, violations or suspected violations of laws, rules, policies, regulations, or this Corporate Compliance Program may not always be clear and may require complex judgment. A compliance contact form has been established for any employee to submit questions about compliance or to report a suspected violation of policy. The form is completely anonymous and is available 24 hours a day, 7 days a week. Individuals are also encouraged to be open and candid in discussing any compliance issues with their manager.

Internal Reporting Compliance Concerns

All employees are required to report any concerns about conflicts of interest, violations or suspected violations of laws, rules, policies, regulations, or this Corporate Compliance Program. Employees may report any such concerns using the compliance contact form.

Confidentiality

On the compliance contact form, employees have the option of identifying themselves or make an anonymous report. It is important that employees have confidence and trust in the Company in knowing that all efforts will be made to conceal the identity of the reporter and the report being made, to the extent possible when investigating the matter.

No Retaliation Policy

Every employee has the responsibility to report to the Company any suspected violation of law or policy by another employee or agent of the Company. Employees can report such violations without fear of retribution or retaliation. Employees, who threaten, retaliate against or harass any person who has reported a compliance concern shall be subject to disciplinary action up to and including termination.

External Compliance Communication

External parties can contact the Medicure Compliance department by calling 1-800-509-0544 then selecting option 3, then option 1, or by emailing compliance@medicure.com.

Investigations and Corrective Action

An essential goal of the Corporate Compliance Program is to identify any unethical or unlawful policy violations and to take appropriate corrective actions in order to discipline and prevent these violations. We foster a culture in which problems and concerns relating to compliance are brought to light, investigated, and remediated.

We are committed to investigating and addressing any reports of suspected policy violations while seeking to ensure that all reported violations are handled in a uniform and evenhanded manner, and in a manner designed to promote compliance with Company policies.

Monitoring and Auditing

A key aspect to the Corporate Compliance Program is periodic monitoring and auditing of employee compliance with policies and procedures to assess whether elements of the Corporate Compliance Program have been satisfied. For example, assessments may include whether, for a defined risk area, standards have been developed, dissemination and training around these standards have been conducted, a mechanism for determining adherence to these standards is in place, an investigation into alleged misconduct was commenced, and appropriate corrective action, if any, has been taken.

The monitoring and auditing plan is reasonably designed to detect violations by an organization's employees or agents. The monitoring and auditing plan will also maintain and enhance the effectiveness of internal controls by assessing changes to laws, regulations, or business activities affecting the Company.

Recordkeeping and Retention

Unless otherwise specified, records pertaining to the implementation and maintenance of the Corporate Compliance Program shall be maintained with the Compliance Officer in the Corporate Compliance Program files. In some cases, training records and other compliance documents will be maintained within the specific compliance function or discipline.