Annual Declaration of Compliance pursuant to California Health and Safety Code §§ 119400 – 119402 Assertio Holdings, Inc. (Assertio)

Assertio has established and maintains a comprehensive Compliance Program that is consistent with the requirements of California Health and Safety Code sections 119400 and 119402. As required by California Health and Safety Code section 119402, with specific reference to the provision of gifts, promotional material, or items or activities that a pharmaceutical company may provide to an individual medical or healthcare professional, Assertio has established an aggregate, annual dollar limit of $2,500 on promotional items and/or meals directed to an individual medical or healthcare professional who resides or practices in California. The dollar limit is a maximum only. Assertio declares that, to the best of our knowledge, and based on our good faith understanding of the statutory requirements of the California Health & Safety Code sections 119400 and 119402, we are in compliance with our comprehensive Compliance Program. Copies of this declaration and the Comprehensive Compliance Program for Sales and Marketing Activities may be obtained by calling Assertio’s Confidential Alertline at 1-800-779- 3381 or from Assertio’s website at www.assertiotx.com.

Date: July 1, 2020