Stiefel Laboratories, Inc.
Declaration of Compliance - State of California

July 1, 2009 - June 30, 2010

Stiefel has established an effective Corporate Compliance Program ("Program") in accordance with the April 2003 "Compliance Program Guidance for Pharmaceutical Manufacturers," published by the Office of Inspector General, U.S. Department of Health and Human Services.

The Stiefel Corporate Compliance program includes:

· The appointment of a dedicated Global Ethics & Compliance Officer

· Oversight by Stiefel's Executive Leadership through a Compliance Committee

· Documented compliance policies and procedures

· Regular and effective compliance education and training

· Open lines of communication, including a toll-free number for reports

· Monitoring and auditing activities to evaluate compliance with the Stiefel Program

· Procedures for responding to identified problems and implementing corrective action

To the best of our knowledge and based upon our good faith understanding of the statutory requirements, Stiefel has established a comprehensive compliance program in accordance with the requirements of California Health and Safety Code §§119400 - 199402 and complies with the Program in all material respects. Additional information regarding the Compliance Program and this declaration can be obtained by contacting the Compliance Office at 1-770-945-0101.

/s/ Charles W. Stiefel
Chairman of the Board, President and Chief Executive Office
June 30, 2009