This Code of Business Conduct (the “Code”) covers a wide range of business practices and procedures. It does not cover every issue that may arise but establishes important principles to guide officers, directors and employees of Aton Pharma, Inc. (the “Company”). Illegal, unethical, or dishonest conduct violates this code. The Code includes limits on gifts or incentives to health care professionals. For more information about the Code, please contact Todd Wallach, CFO, at 609-671-9010.

As part of its Code of Business Conduct, Aton Pharma is committed to complying with all applicable federal and state laws, regulations, policies, including the Anti-Kickback Law, the Civil Monetary Penalty Statute, the Office of Inspector General (“OIG”) Compliance Guidance for Pharmaceutical Industry, and the Pharmaceutical Researchers and Manufacturers of America (“PhRMA”) Code of Interactions with Health Care Professionals.