Creating a recovery provision. The provision of the Company Integrity Agreement, known as the Executive Financial Recoupment Program, states that GSK implements a program that “reports the risk of cancellation and recovery of up to three years of annual compensation – annual bonuses and long-term incentives – for an executive involved in significant misconduct.” 1 – See 42 U.C 1320a-7a; No. 1320a-7 (b) (7). 2 – The OIG has published a series of compliance program guidelines for different health care providers and applicants. A detailed list of these OIG compliance programs can be find on the OIG website: oig.hhs.gov/ fraud/complianceguidance.html. 3 – 31 U.S.C No. 3729 to 3733. 4 – 42 U.C No. 1320a-7a. 5 – 31 U.C.

No. 3801 to 3812. 6 – DOJ and HHS, HCFAC annual report for GJ 2011, February 1, 2012. 7 – Id. 8 – Id. 9 – 42 U.S.C. 10 – 42 U.S.C No. 1320a-7b (b). 11 – 42 U.C 12 – 42 U.C No. 1320a-7 (a).

13 – 42 U.S.C No. 1320a-7 (b). 14 – 42 U.C No. 1395nn (a) (1). 15 – 31 U.S.C 16 – GAO Report, “Health Care Fraud – Types of Providers I Medicare, Medicaid, and the Children`s Health Insurance Cases,” GAO 12-820, 27. September 2012. 17 – Id. to 29. 18 – Id.

to 31. 19 – False Claims Act, 31 U.S.C. 20 – See comparative agreements between the United States and Temple University – Of the Commonwealth System of Higher Education, valid May 14, 2012. 21 – See www.oig.hhs.gov. 22 – Communication, 74 FR 52964, 9 October 2009. 23 – See www.oig.hhs.gov/fraud/cia/faq.asp. Detailed information and questions about the CIA and IROs can be found strategicmanag.wpengine.com 24 – 24 “Building a Partnership for Effective Compliance,” The Third Government-Industry Roundtable, July 30, 2001, www.oig.hhs.gov/fraud/docs/compliance. 25 – 25 id. to 226 – Id. to 3. 27 – See www.oig.hhs.gov/fraud/cia/cia_list.

28 – “Frequently asked questions about IRO Indepen-dence,” www.oig.hhs.gov. 29 – Id. at 1:2.30 – GAO, Government Auditing Standards, July 2007 Revision (Yellow Book), GAO-07-731G, available at www.gao.gov/assets/80/76968.pdf. 31 – OIG Report “Focus on Compliance – The Next Generation of Corporate Integrity Agreements,” October 9, 2012. 32 – Id. In addition to the high payments, Abbott has agreed to several other measures, including a five-year enterprise integrity agreement, in which the company`s board of directors must verify and certify the effectiveness of its compliance program. Abbott will pay $800 million to settle civil charges shared between the federal state and the federal states, $700 million for a criminal fine and $100 million to the states to resolve consumer protection issues. These amounts have been set aside in advance of today`s agreement. “Following OIG`s joint investigation with our federal and regional partners, Abbott Laboratories is entering one of the largest colonies in the pharmaceutical industry and is paying $1.5 billion for the illegal promotion of its drug Depakote, including for patients in care homes with dementia,” said Daniel R, HHS Inspector General.