Compliance Program
Verona Pharma plc and its subsidiaries (together “Verona Pharma”) is committed to lawful and ethical business conduct, in compliance with all applicable laws, regulations, guidelines, and codes of the countries in which it operates. Our strong commitment to integrity and transparency is critical in building and maintaining the trust of our patients, healthcare providers and regulators.

Verona Pharma has an established robust Compliance Program in accordance with the guidelines set forth in the United States Department of Health and Human Services Office of Inspector General’s (OIG) “Compliance Program Guidance for Pharmaceutical Manufacturers” and the Pharmaceutical Research and Manufacturers of America (PhRMA) “Code on Interactions with Healthcare Professionals.”

Our program is tailored to meet the specific needs of Verona Pharma and is continuously assessed and updated for effectiveness and to meet the needs of the regulatory environment and our evolving needs.

Compliance Leadership
The Chief Compliance Officer along with the Compliance Department are responsible for overseeing the implementation and administration of Verona Pharma’s Compliance Program. Verona Pharma has also established a Compliance Committee that meets regularly to address the company’s compliance activities.

Policies and Procedures
Verona Pharma has implemented relevant written policies and procedures consistent with applicable laws and regulations as part of our commitment to ethical business conduct. The policies and procedures are designed to ensure adherence to the evolving regulatory landscape, as applicable to Verona Pharma’s business operations.

Code of Business Conduct and Ethics
Verona Pharma’s Code of Business Conduct and Ethics applies to all employees, executive officers, and members of the Board of Directors of Verona Pharma. It is a public record of our commitment to upholding the highest ethical standards through our company values and business principles. We work to meet the standards set out in our Code because we understand that long-term success depends on us making the best choices for Verona Pharma and the many people we serve.

Our Code of Business Conduct and Ethics can be found here.

Education and Training
Educating and training our employees on their legal and ethical duties consistent with relevant policies, laws, and regulations is an essential element of our Compliance Program. Our policies, standards, and procedures are clearly communicated to all staff and business partners throughout the training process. Our employees are held to our company standards, which are consistently reviewed and refreshed to identify new areas for training as required to preserve compliance and integrity.

Lines of Communication
Verona Pharma is dedicated to cultivating an environment that promotes open communication between management and employees about our Compliance policies and procedures. Employees are encouraged to approach with questions or concerns and to report any potential violations or suspected improper practices. To support transparency and honesty, we have embraced principles of anonymity, confidentiality, and non-retaliation for any employee who reports or makes a good faith effort to report suspected misconduct. We provide several avenues for making reports, including our anonymous hotline and web portal.

Auditing and Monitoring
To ensure ethical and compliant business practices, Verona Pharma conducts monitoring and auditing of our business activities. Potential risk areas are identified and evaluated to determine the extent and frequency of our monitoring and auditing efforts.

Responding to Potential Violations and Remediating Issues
Potential and actual violations of company policies and applicable laws and regulations are treated with necessary corrective or disciplinary action as determined by Verona Pharma. We aim to investigate and address all matters – potential, suspected, or confirmed violations of laws or policies – with appropriate responses to ultimately identify and correct improper behavior, prevent future occurrence, and continuously refine the compliance program. We engage with relevant stakeholders to determine the appropriate corrective and preventive actions to take in response to misconduct and violations.

Declaration of Compliance
Verona Pharma’s Compliance Program has been designed in accordance with the Compliance Program Guidance for Pharmaceutical Manufacturers published by the Office of the Inspector General of the US Department of Health and Human Services. To the best of our knowledge, based upon current tracking and monitoring systems, Verona Pharma is in compliance with its own Compliance Program and with California Health & Safety Code 119402, including the established annual spending limits in California as of July 2024.