California Annual Declaration of Compliance

September 26, 2025

Journey Medical Corporation (“Journey”) has developed a Comprehensive Compliance Program (“Compliance Program”) that is in compliance with the California Health & Safety Code §119400-119402, the HHS OIG Compliance Program Guidance for Pharmaceutical Manufacturers, and the PhRMA Code on Interactions with Healthcare Professionals.  Journey’s Compliance Program is tailored to size, organizational structure, and resources of the company, and is reasonably designed to prevent and detect compliance violations in accordance with the HHS OIG Compliance Program Guidance for Pharmaceutical Manufacturers.  As of September 10, 2025, Journey hereby declares in good faith to the best of its knowledge, information, and belief that it is, in all material respects, in compliance with its Compliance Program and the requirements of California Health & Safety Code §119400-119402.   

Journey has developed and implemented elements of its Compliance Policy to address certain issues uniquely raised by the California law.  Journey will periodically assess the effectiveness of its Compliance Policy and may modify aspects as needed to provide necessary enhancements.  Additionally, Journey has established an annual aggregate limit of $2,000 per HCP licensed in California for expenditures associated with various activities, such as meals provided in connection with promotional or informational discussions or scientific exchange, and educational items intended to enhance patient care.  Excluded from the limits are drug samples, patient educational materials, financial support for continuing medical education forums or health educational scholarships, and fair market value payments made for legitimate contracted services provided by an HCP to Journey.

A copy of this California Annual Declaration of Compliance can be obtained by emailing compliance@jmcderm.com.