Ethics & Compliance

Crinetics has appointed a Compliance Officer who is responsible for developing, operating and monitoring the Compliance Program and is advised regularly by the Crinetics Compliance Committee. The Compliance Officer reports directly to the Chief Legal Officer and has direct access to other members of Crinetics’ senior management and the Board of Directors. The Compliance Officer provides a compliance update to the Board of Directors at the regularly scheduled Board meetings and on an as-needed basis.

Crinetics has established a Compliance Committee to advise the Compliance Officer and assist in the implementation of the Compliance Program. The Compliance Committee is comprised of members from functional units across the Company and meets on a regular basis to consider compliance and policy issues encountered in the various business areas.

Crinetics has established written policies and procedures to ensure compliance with various laws and regulations. The standards set forth in these policies and procedures outline our commitment to compliance and corporate accountability and apply to individuals based on their job function and responsibilities.

Crinetics has policies and procedures in place that address risk areas identified in the OIG Guidance and comply with the Pharmaceutical Research and Manufacturers of America voluntary “Code on Interactions with Healthcare Professionals” (the “PhRMA Code”).

Crinetics has also established spend parameters, which include an annual upper dollar limit of $2,500 on meals or promotional items directly towards an individual California healthcare professional (HCP). We track and monitor these spending parameters to the best of our ability, using available resources, and will modify such parameters, if necessary. On rare occasions, management may authorize additional spending based on specific circumstances.

Crinetics has developed general compliance training on the Compliance Program and the Code of Conduct and Ethics as well as applicable training on policies and procedures applicable to the job function and role of the individuals. Training includes how to report compliance concerns through appropriate channels, including reporting anonymously either online or via telephone.

Crinetics has established a variety of internal communication tools for communicating compliance issues and concerns. Individuals are required to report known or suspected violations of laws, or the Crinetics’ policies and procedures, to their direct managers or the Compliance Officer. Any reported information will remain confidential to the extent possible consistent with law and our need to investigate the potential violation. We will not retaliate or take adverse action against anyone who, in good faith, seeks help or who reports known or suspected violations. If the individual who reports a violation is directly involved in the violation, the fact that they reported the violation will be given appropriate consideration in any resulting action.

While individuals are encouraged to speak with their direct manager or to the Compliance Officer, those who wish to anonymously raise concerns about potential violations of law or our policies and procedures may do so either online or via telephone through our EthicsPoint Helpline. Reports will be forwarded to the Compliance Officer for response or investigation.

Crinetics will conduct auditing and monitoring activities designed to assess compliance with the Compliance Program and our various policies and procedures. The nature and frequency of these activities varies according to a variety of factors, including new regulatory requirements. Results are reported to the Compliance Committee.

It is the Crinetics’ policy to respond promptly to violations of law or our policies and procedures and take appropriate action. While each situation will be considered on a case-by-case basis, Crinetics is committed to taking appropriate action to address the violation and deter any future violations. Disciplinary action for non-compliance may include a broad range of disciplinary measures, up to and including termination of employment or a service agreement.

We respond promptly to potential violations of law or Crinetics policies and procedures. The Compliance Officer oversees the investigations process, and the response and level of investigation depends on the reported or detected issue. We will assess whether disciplinary action is appropriate, and whether a violation is due in part to gaps in our policies, procedures, training or internal controls, and take action to prevent future violations.