Amneal Code of Conduct

3 December 2019 A Message from Chirag and Chintu Patel 4 Our Company 6 We make healthy possible 7 High Standards 7 Real Progress 7 Genuine Partnerships 7 Introduction 8 Who is covered by the Code? 9 Who develops the Code? 9 Who approves the Code? 9 Who is responsible for complying with the Code? 9 How is the Code enforced? 9 Amneal’s Ethics & Compliance Program 10 Following Laws and Regulations 12 Working Together 14 Business Language 15 Open Door Policy 15 Equal Employment Opportunity 15 Workplace Security 15 Hostile Action 16 Harassment 16 Discrimination 16 Personal Relationships 16 Conflicts of Interest 17 Gifts 18 Giving Gifts 19 Accepting Gifts 20 Outside Employment 20 Business Relationships 20 Relationships with Friends and Family Members 20 Business, Scientific and Professional Organizations 21 Business Opportunities 21 Environment, Health and Safety 22 Understanding National and Local Requirements 23 Disposal of Hazardous Materials 23 Reporting Hazardous Conditions and Events 23 Use of Protective Equipment and Apparel 23 Reporting Potential Health Risks 23 Company Assets and Records 24 Use of Corporate Funds and Assets 25 Use of Amneal Technology Assets 25 Record Keeping Policies 26 Confidentiality and Privacy 27 Confidential Information 28 Confidentiality Agreements 28 Privacy and Data Protection 28 Protecting Electronic Communications and Data 29 Investor Relations and Communications 30 Public Disclosure and Company Records 31 Prohibition of Insider Trading 31 Insider Trading by Family Members 33 News Media and Investor Inquiries 33 Pharmaceutical Compliance 34 Pharmaceutical Laws 35 Quality 35 Safety 36 Product Advertising and Promotion 36 Healthcare Fraud and Abuse Laws 37 Global Business Compliance 38 Fairness and Integrity in the Marketplace 39 Antitrust, Unfair Competition and Restraint of Trade 39 Copyright Laws 40 Export Controls and Trade Sanctions 40 Anti-Corruption 40 Gifts, Meals and Entertainment 42 Working with Government 44 Payments to Government Officials 45 Gifts to Government Officials 45 Making False Reports to Government Agencies 45 Political Contributions 45 Charitable Contributions 46 Reporting Possible Violations 48 How to Report Violations 49 Accessing the Amneal Ethics & Compliance Hotline 49 Non-Retaliation Policy 49 Investigation of Complaints 50 Disciplinary Action 50 Acknowledgement Requirements 52 Nine Simple Questions 54