Steps Taken to Strengthen GRx

1. The installation of a new management team led by Chief Executive Officer and President Paul Nick, a certified public accountant with big accounting firm experience and formerly the Controller of the Company. 
2. The hiring of new outside General Counsel and acting Compliance Officer, Ira Halperin. Ira is an experienced corporate attorney from Meltzer, Lippe, Goldstein & Breitstone, LLP, a prominent Long Island law firm.  
3.  Appointment of Roscoe C. Howard, Jr., of the law firm of Barnes & Thornburg LLP as an independent monitor to do a full review and monitoring of Guaranteed Returns’ compliance programs and internal controls and the implementation thereof.  Mr. Howard was the United States Attorney for the District of Columbia from 2001-04.  Prior to being appointed by the President to that position, Mr. Howard was an Assistant United States Attorney in both the District of Columbia and the Eastern District of Virginia. 
4. The execution of an escrow agreement with the Company’s bank, pursuant to which all funds received from manufacturers on behalf of customers are analyzed by an independent third party accounting firm before being released to the company.
5. The adoption of a Code of Business Conduct and Corporate Compliance Program (the “Code”) memorializing various policies, procedures and internal controls designed to ensure law abiding and ethical behavior.

6. The formation of a formal Corporate Compliance Committee that is responsible for management oversight of the Corporate Compliance Program; the committee also supports Senior Management in ensuring the effectiveness of the Program.

7. The adoption of an Employee Reporting Hotline which enables any employee to anonymously report anything he/she observes.
8. The adoption of a Policy on Procurement Integrity and Other ‘Off Limits’ Information that governs bidding on government contracts.

9. The introduction of a product aging services program to existing and new customers, giving customers three options with respect to the treatment of their “in-dated product.” By clearly offering these options to our customers, the Company has eliminated any potential misunderstanding about the treatment of “in-dated products”.
10. The launch of a new program called ReverseLink Direct Pay (RLDP). This program enables quick payments directly to your facility from manufacturers or as drop-ship credits from your wholesaler. 
11. Control of Mr. Volkes’ voting rights as sole shareholder at the company was transferred to an independent trustee pursuant to a voting trust agreement. The independent trustee is a former state prosecutor who served over 21 years in the Kings County District Attorney’s office, where he served as Chief of the Supreme Court Trial Bureau (supervising over 300 Assistant District Attorneys), and as confidential assistant to the District Attorney.
12. Dean Volkes stepped down as an officer or director of Guaranteed Returns soon after the indictment, over two years ago, and is no longer involved in the operation of the business and will not be involved going forward. 
13. Donna Fallon stepped down as an officer of Guaranteed Returns soon after the indictment and is no longer involved in the management or control of Guaranteed Returns and will not be involved going forward.