About inVentiv Health’s Compliance Hotline

Frequently Asked Questions (FAQ's) About the inVentiv Health Compliance Hotline

About inVentiv Health's Compliance Hotline Reporting ? General Reporting ? Security & Confidentiality Tips & Best Practices

About inVentiv Health's Compliance Hotline

What is the inVentiv Health Compliance Hotline? The Compliance Hotline for inVentiv Health, Inc. and its subsidiaries ("inVentiv Health") is a comprehensive and confidential reporting tool to assist management and employees to work together to address fraud, abuse, and other misconduct in the workplace, all while cultivating a positive work environment.

Why do we need a Compliance Hotline? We believe that our employees are our most important asset. By creating open channels of communication, we can promote a positive work environment and maximize productivity. The Compliance Hotline is a critical component of inVentiv Health's overall compliance program. Among other things, the Compliance Hotline offers an anonymous reporting vehicle (where such reporting is permitted by local law) to address potential accounting and auditing fraud directly to the Audit Committee of the Board of Directors in accordance with inVentiv Health's Procedures for Handling Accounting, Auditing and Internal Control Complaints. An effective reporting system will augment our other efforts to foster a culture of integrity and ethical decision-making.

? 2013 inVentiv Health, Inc. All Rights Reserved

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Frequently Asked Questions (FAQ's) About the inVentiv Health Compliance Hotline

Reporting ? General

May I report using either the Internet or the telephone? Yes. With inVentiv Health's Compliance Hotline, you have the ability to file a confidential, anonymous report via either the telephone or the Internet (to the extent anonymous reporting is permitted by applicable law).

What type of situations should I report? The inVentiv Health Compliance Hotline is designed for employees to report any potential violation of our Code of Business Conduct and Ethics or other concern you may have.

If I see what I believe may be a violation, can I report it to my manager or Human Resources instead of calling the Compliance Hotline? When you observe or learn of behavior that you believe may violate our Code of Business Conduct and Ethics, we expect you to report it. Our compliance program offers you many avenues for reporting, including speaking to your direct supervisor or more senior management, your local Human Resources representative or more senior or corporate Human Resources management, your business unit attorney or the General Counsel or the Chief Compliance Officer of inVentiv Health. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances that we offer the Compliance Hotline. We would rather you report to the Compliance Hotline, either with identifying information or anonymously (as permitted by local law) than keep the information to yourself.

Does management really want me to report? Yes. In fact, we need you to report. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize potential negative impact on the company and our people. Also, offering positive input may help identify issues that can help improve corporate culture and performance.

? 2013 inVentiv Health, Inc. All Rights Reserved

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Frequently Asked Questions (FAQ's) About the inVentiv Health Compliance Hotline

Where do these reports go? Who can access them? The inVentiv Health Compliance Hotline is operated by a third party vendor with considerable experience in this type of reporting program. Reports are entered directly into the third party's secure server. The reports are then made available to specific individuals within the company who are charged with evaluating and triaging them for handling based on the type of violation and location of the incident. Information in the reports is maintained as confidentially as possible under the circumstances.

Reporting ? Security & Confidentiality

It is my understanding that any report I send from a company computer generates a server log that shows every web-site that my computer connects with, and won't this log identify me as a report originator?

Our vendor does not generate or maintain any internal connection logs with IP addresses, so no information linking your computer to the vendor's server is available. If you feel uncomfortable making a report from on your work computer, you have the option of using a computer outside our work environment (such as one located at an Internet caf?, at a friend's house, etc.) through the vendor's secure website.

Can I file a report from home and still remain anonymous? A report from home, a neighbor's computer, or any Internet portal will remain secure and anonymous (except where local law restricts anonymous reporting, in which case you will be so advised). An Internet portal never identifies a visitor by screen name and our vendor's system strips away Internet addresses so that anonymity is maintained.

Is the telephone toll-free hot line confidential and anonymous too? Yes. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer will type your responses into the vendor's Web site. These reports have the same security and confidentiality measures applied to them during delivery.

? 2013 inVentiv Health, Inc. All Rights Reserved

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Frequently Asked Questions (FAQ's) About the inVentiv Health Compliance Hotline

What if I want to be identified with my report?

There is a section in the report for identifying yourself, if you wish. You are encouraged to provide as much identifying information as you are comfortable providing, as this will allow inVentiv to more thoroughly review and address your concern. If you do choose to provide your name, your identity and the fact that the report was made will be kept as confidential as possible under the circumstances.

These answers refer to keeping the information in my report "as confidential as possible under the circumstances." What does that mean?

inVentiv Health's Compliance Hotline is a critical tool for detecting and preventing possible violations of the law, our Code of Business Conduct and Ethics or company policy. In order to address concerns you raise through the Compliance Hotline, it is necessary to disclose some of the information provided in any report you make. For example, if you report potential misconduct within a particular department, some review of that misconduct must occur. Information from your report and any additional details you provide will need to be disclosed to the extent necessary for a full and fair review of the matters you have raised. At the same time, inVentiv Health does not intend to disclose more information than necessary for these purposes.

Am I protected in any way if I raise a concern through the Compliance Hotline?

Yes. If you raise an issue about a possible violation of the law or the Code of Business Conduct and Ethics or other inVentiv Health policy, you will be protected from retaliation. It is a violation of the Code for any adverse action to be taken against you simply because you have communicated a potential violation or other legal or ethical concern in order to initiate a good faith report of such a violation or to seek clarification with respect to such person's conduct. If you believe you have been retaliated against in violation of the Code, you should report your concerns through one of the channels described here or in the Code.

? 2013 inVentiv Health, Inc. All Rights Reserved

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Frequently Asked Questions (FAQ's) About the inVentiv Health Compliance Hotline

Tips & Best Practices

I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?

It's your responsibility to do so. inVentiv Health is committed to acting ethically in all we do. Unethical conduct has the potential to hurt the company, its reputation and its employees. Reporting such conduct is critical. As set forth in our Code of Business Conduct and Ethics:

The responsibilities of persons covered by the Code include: Complying with the Code. Company policies and procedures and all laws, rules and regulations applicable to the Company wherever it does business worldwide; Acting ethically and honestly in performing their job duties; Seeking guidance when necessary on ethical or legal questions; and Reporting suspected violations of the Code, Company policies or procedures or applicable law through the channels described in the Code.

I am not sure if what I have observed or heard is a violation of company policy, or involves unethical conduct, but it just does not look right to me. What should I do?

File a report. As noted in the answer above, it is also your obligation to seek guidance when necessary on ethical or legal questions. The Compliance Hotline is offered to you as a means of doing so. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you weren't sure.

What if I remember something important about the incident after I file the report? Or what if the company has further questions for me concerning my report?

When you file a report through the Compliance Hotline, either online or by telephone, you receive a unique user name and are asked to choose a password. You can return to the Compliance Hotline system again either by Internet or telephone and access the original report to add more detail or answer questions posed by a company representative and add further information that will help resolve open issues. We strongly suggest that you return to the site in the time specified to answer company questions.

? 2013 inVentiv Health, Inc. All Rights Reserved

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