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(Adopted September 1, 2015)

The Board of Directors (the "Board") of Aradigm Corporation, a California corporation (the "Company") has adopted these Corporate Governance Guidelines ("Guidelines") to assist the Board in the exercise of its responsibilities and to best serve the interests of the Company and its shareholders. These Guidelines should be interpreted in the context of applicable laws and the Company’s Articles of Incorporation, Bylaws and other corporate governance documents. These Guidelines are intended to serve as a flexible framework within which the Board may conduct its business and not as a set of legally binding obligations. These Guidelines are subject to periodic review by the Board and the Nominating and Corporate Governance Committee, which may recommend to the Board that they be modified, amended and/or expanded at any time, when appropriate.

I. Board Size
II. Roles and Responsibilities of the Board and its Committees
III. Selection and Composition of the Board
IV. Board Operations
V. Executive Succession Planning and CEO Performance
VI. Annual Self-Evaluation

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