Effective July 18, 1997

This Policy addresses use of, access to and disclosure of past, present, and future messages and information created, sent, received, or stored via the Company's Electronic Communications Systems.

This Policy applies to all employees, temporary employees, contractors, and consultants (referred to, for purposes of this Policy, as "Users") of Pharmaceutical Corp Inc., its divisions and any of its wholly owned subsidiaries including, Pharmaceutical Corp Pharmaceuticals (PCP), and Dermik Laboratories, Inc. (collectively referred to as the "Company"), who are based in the United States (including Puerto Rico) who have access to or use of the Company's Electronic Communications Systems.

"Electronic Communications Systems" include the Company's electronic mail ("E-Mail"), intranet, voice messaging, and video conferencing systems. This includes MS Exchange, MS Mail, MS Schedule+, Team-links, ALL-IN-1, cc:Mail, PROFS and DENDRITE. "Electronic Communications Systems" also include all information, messages and documents sent, received or stored on Company equipment or any external public or private network to which the Company provides access, including the Internet or World Wide Web (the term "Internet" is used in this Policy to refer to all external networks).

General

Electronic Communications Systems are Company property and are intended solely for carrying out the Company's business. All messages and information created, sent, received, or stored using an Electronic Communications System are the property of the Company.

Intended Use - Electronic Communications Systems should be for Company purposes only. Common sense should be used in sending messages; all messages should be businesslike. The sender is responsible for ensuring that mail is properly addressed so that it is sent only to those intended to receive the messages.

Prohibited Use - The Electronic Communications Systems are not intended for personal use. Electronic Communications Systems should not be used for gossip. No message that is sent may be vulgar, sexually explicit, defamatory, harassing, or discriminatory with respect to age, race, sex, sexual orientation, religious or political beliefs, national origin, or disability. No one may send or receive messages or information using the Electronic Communications Systems in violation of copyright law or any other laws.

No one, without the Company's permission, may use Electronic Communications Systems to solicit or proselytize for commercial ventures, religious or political causes, outside organizations, or other non-job-related solicitations. The Company's Electronic Communications Systems may not be used in a way that may be disruptive or offensive to others.

Proprietary information (including trade secrets), confidential information, and any other information which is of value to the Company cannot be disclosed to any third party without the permission of the User's supervisor and/or the Company's legal counsel and should not be sent via an Electronic Communications System unless security is assured.

Unauthorized Access - No one may retrieve or read any E-mail messages that are not addressed to them without his or her supervisor's authorization or the addressee's permission. Under no circumstance should anyone share or divulge their password with another person except as provided for in this Policy.

Non-Company Personnel - No one should permit any non-Company personnel to access Electronic Communications Systems (including E-Mail or the Internet) without permission from his or her manager or supervisor.

Chat Lines/Rooms, USENET and other News Groups, and bulletin boards - No one may send messages on a public chat line/room via the Internet without first obtaining approval from his or her supervisor for each message. No one may post messages on any public USENET/News Group, etc. via the Internet without first obtaining approval from his or her supervisor for each message. In no event shall anyone transmit nonapproved drug information, proprietary information, or any other Company information that is not public. No one should represent that they speak on behalf of, or represent, the Company on any issue without prior written approval from an Officer of the Company.

Company Access

All messages created, sent, received, or stored on Electronic Communications Systems are Company records. The Company has the right to review, disclose and use these records without notice, at any time and for any purpose. This right includes the right to monitor any and all uses of the Electronic Communications Systems. It should also be noted that anything created, sent, received or stored on the Electronic Communications Systems, which is then deleted may still be accessed by the Company. By using the Electronic Communications Systems, a User consents to these Company rights.

At the request of his or her supervisor or another person authorized by the Company, a User must disclose all IDs and passwords utilized by the User in connection with Electronic Communications Systems.

Responsibility

A violation of this Policy may result in disciplinary action, including, but not limited to, termination of employment. We must take this Policy seriously.

Everyone using the Electronic Communications Systems is responsible for complying with and carrying out the requirements of this Policy. All managers and supervisors are responsible for monitoring compliance. Any violation of this Policy should be immediately reported to the appropriate manager or supervisor. Failure by managers or supervisors or any other Company representative to report or act on any violation of this Policy does not constitute waiver by the Company of any portion of this Policy.

Everyone receiving documents, messages, E-Mail, etc. via Electronic Communications Systems is responsible for notifying the sender of such documents, messages, E-Mail, etc. that the Company reserves the right to monitor, access, review, copy, use and disclose such communications at any time and for any purpose.