Amneal Code of Conduct

45 December 2019 Payments to Government Officials We have a responsibility to obey all laws governing our contacts with government officials in any country where we may do business. Amneal colleagues must be familiar with and follow the laws that govern payments to government employees, including the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act 2010. A government official is an individual, whether elected or appointed, who holds a legislative, administrative, or judicial position of any kind. This includes any person who performs public functions in any branch of the national, local, or municipal government, or who exercises a public function for any public agency or public enterprise (e.g., public health agencies and officers exercising public functions in state-owned enterprises). A government official can also be a political party, an official, employee, or agent of a political party, a candidate or prospective candidate for political office, an international governmental organization, a state-owned enterprise, or an entity owned or controlled by a government unit. Healthcare Professionals employed by public hospitals are also considered government officials. Amneal colleagues and representatives are prohibited from directly or indirectly making, promising, authorizing, or offering anything of value to a government official on behalf of Amneal. Gifts to Government Officials United States federal law and Amneal policy specifically prohibits making any offer, promise, or gift of any value to an employee, agent or official of the federal government, subject to specific limitations. This includes any Congressperson, Senator, a member of a Congressperson’s or Senator’s staff, or any other Congressional or Senate employee. Many governments around the world have very strict rules regulating the provision of gifts, entertainment, meals, favors, or anything of value to government employees and union officials. Amneal will comply with all such applicable rules as required. If you work with public officials, be aware that even simple offers such as purchasing a meal or refreshments may be unacceptable or even against the law. Always contact the Corporate Compliance or Legal departments before providing any gift or entertainment to a public official. Making False Reports to Government Agencies Amneal requires that all information provided to any government agency be true and complete to our best knowledge in all material respects at the time it is provided. Hiding or concealing any material fact that would make a statement or report misleading by its omission is also likely to be illegal and is against Amneal policy. Political Contributions Amneal encourages colleagues to be involved personally in their communities and in political affairs. However, no colleague shall directly or indirectly use or contribute funds or assets of Amneal to any political party, candidate or campaign, unless it is an accepted practice and lawful. Any contribution must be approved in advance by the Chief Financial Officer, General Counsel, and Chief Compliance Officer. Colleagues are not prohibited frommaking voluntary personal contributions to any candidate, political party or cause. However, these contributions are not reimbursable by Amneal, either directly or indirectly. Colleagues may not solicit contributions from other colleagues during business hours and may not use Company assets or resources, including the Amneal name or logo, in connection with personal political activities.