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SI-BONE INC. COMPREHENSIVE COMPLIANCE PROGRAM

SI-BONE, Inc. is committed to establishing and maintaining an effective Compliance Program in accordance with "Compliance Program Guidance for Pharmaceutical Manufacturers," published by the Office of Inspector General, U.S. Department of Health and Human Services (the "HHS-OIG Guidance"). Our Compliance Program is one of the key components of our commitment to the highest standards of conduct.

Purpose

The purpose of our Compliance Program is to prevent and detect violations of law or company policies. As the HHS-OIG Guidance recognizes, however, the implementation of such a program cannot guarantee that improper employee conduct will be entirely eliminated. Nonetheless, it is our expectation that employees will comply with our Code of Conduct, and the policies established in support of such a Code. In the event that we become aware of violations of law or company policy, we will investigate the matter and, where appropriate, take disciplinary action and implement corrective measures to prevent future violations.
Described below are the fundamental elements of the SI-BONE, Inc. Compliance Program. Consistent with the HHS-OIG Guidance, we have tailored our program to fit the unique environment of our company. We regularly review and enhance our program to meet our evolving compliance needs.

Compliance Program Structure

The core principles of our Compliance Program our set forth in our Code of Conduct. The company from time to time adopts additional policies and procedures to ensure compliance with these core principles. These policies include specific policies governing our interactions with Healthcare Providers. The company has also adopted and is committed to compliance with the AdvaMed Code of Ethics on Interactions with Healthcare Providers.

In accordance with Cal. Health & Safety Sec. 119402(d), The Company has implemented an annual spending limit of $1,500 on promotional materials, items or activities that the company may provide to licensed health care professionals. These materials, items and activities are subject to further restrictions set forth in our Code of Conduct, the AdvaMed Code of Ethics and other applicable policies and procedures.

2011 Annual Written Declaration of Compliance with the SI-BONE, Inc. Comprehensive Compliance Program

SI-BONE, Inc. hereby declares as required by the California Health & Safety Code §119402(e), that to the best of our knowledge, it is in all material respects in compliance with its Comprehensive Compliance Program (http://www.si-bone.com/about/our_company/compliance/) and the relevant requirements of Cal. Health & Safety Code § § 119400-119402.

SI-BONE, Inc. July 1, 2011

Further Information

For a copy of this Declaration, the Comprehensive Compliance Program, or our Code of Conduct, please call 408-207-0700.