Last Updated: May 7, 2026
1. Purpose
This policy describes Company’s right to monitor Practitioner’s compliance with the Practitioner Wholesale Agreement, the MAP Policy, and all Portal Policies. Compliance monitoring protects the integrity of the brand, ensures regulatory compliance, and maintains a fair marketplace for all Program participants.
2. Monitoring Methods
Company may monitor compliance through any of the following methods, at any time and without prior notice:
- Test purchases from Practitioner’s authorized sales channels
- Online monitoring of Practitioner’s website, social media, and other online presence for pricing compliance, claim compliance, and brand guideline adherence
- Lot number tracking to verify Products are being sold through authorized channels only
- Third-party investigators retained by Company to conduct any of the above activities
- Review of publicly available information related to Practitioner’s business, licensure, and credentials
3. Records Requests
Company may request the following records from Practitioner:
- Sales data: Product sales records, including quantities, dates, and lot numbers
- Inventory levels: Current inventory by Product and lot number
- Storage documentation: Evidence of proper storage conditions (temperature logs, facility photos, or other documentation)
Frequency
- Company may make up to two (2) routine records requests per calendar year.
- If Company has a reasonable basis to suspect a violation of the Wholesale Agreement, MAP Policy, or Portal Policies, Company may make additional requests as necessary to investigate the suspected violation.
Response Time
- Practitioner must respond to records requests within fifteen (15) business days of the request, or such other timeframe as specified by Company.
4. Record Retention
Practitioner must maintain purchase and sales records for Products for at least two (2) years from the date of each transaction. Records must include:
- Product name and lot number
- Quantity purchased and date of purchase
- Quantity sold and date of sale
- Storage records sufficient to demonstrate compliance with label requirements
5. Cooperation
Practitioner must cooperate fully and in good faith with all audits, investigations, and records requests. Cooperation includes providing complete and accurate information within the required timeframe.
6. Non-Cooperation
Failure to cooperate with an audit, investigation, or records request — including failure to respond, providing incomplete or inaccurate information, or obstructing an investigation — is grounds for immediate suspension or termination of Practitioner’s participation in the Program.
7. Audit Rights Survive Termination
Company’s audit and monitoring rights survive termination of the Practitioner Wholesale Agreement for twenty-four (24) months following termination.