48117_Amneal Code of Conduct-update 2023 R6.indd

November 2023 Examples of conduct that violate this Amneal policy include: • Agreements or understandings with competitors on price. • Agreements or understandings with competitors to “divide up” customers, products, services, or territories. • “Bid-rigging” (for example, reaching a prior agreement with competitors to govern conduct in the bidding process) or making agreements or reaching understandings with competitors not to bid in public or private procurements. • Agreements or understandings with competitors to disadvantage other competitors. Parties entering into these types of agreements can be prosecuted under criminal law, resulting in significant fines for corporations and fines and imprisonment for the colleagues involved. An unlawful agreement on “price” can cover a broad range of agreements among competitors that directly or indirectly afect the price of goods or services. This includes, for example, agreements on price ranges, minimum prices, list prices, advertised prices, pricing formulas, discounts, rebates, profit margins, credit and warranty terms, or other terms of sale. An “agreement” or “understanding” need not be in writing for it to be unlawful. It can be oral or inferred from the conduct of the parties, as in the following examples: • An informal observation to a competitor about a company’s likely future prices; • Comments to a competitor about the desirability of an entire industry following a price increase; or • Comments to a competitor about the desirability of ceasing discounts to certain customers. These kinds of situations have each been used (along with other circumstantial evidence) to charge companies and individuals with criminal price-fixing. It is for this reason that you should avoid any conduct or activity, formal or informal, from which even an appearance of improper conduct could be drawn. The obligation to scrupulously avoid even an appearance of impropriety applies in business settings, as well as to communications with competitors in casual social settings (golf games, civic events, etc.). In addition, a supplier in one market may be a competitor in another. Conversations that are wholly appropriate in the context of a supplier relationship may be inappropriate when discussions shif to issues relating to areas of competition. Contact a Legal Department representative if you have questions about the applicability or implication of antitrust laws in relation to Amneal’s business activities. For more information see the Global Antitrust Policy. Copyright Laws Amneal respects copyrighted works and copyright laws in the various countries where we do business. No Amneal colleague may reproduce, adapt, distribute, perform, or display any copyrighted work in any form (for example, print, audio, video, or electronic) without the permission of the copyright owner. Violations can result in severe penalties for both the individual and Amneal. Contact a Legal Department representative if you have any questions about your ability to use a copyrighted work. Export Controls and Trade Sanctions Export controls are laws that prohibit, control or limit transfers of both products and information among countries. Amneal complies with all United States federal import and export laws and regulations. These laws restrict transfers, exports, and sales of products or technical data from the United States to certain prescribed countries and persons as well as re-export of certain items from one non-U.S. location to another. In addition, certain countries and parties are subject to trade and economic sanctions by the governments of countries in which Amneal operates, which in many cases prohibit even ordinary sales, research, manufacturing, and other commercial relationships. Different export clearance and recordkeeping requirements may apply to exports from each jurisdiction in which Amneal operates. If you are involved in importing and exporting goods and data, you are responsible for knowing and following these laws. For more information see the Global Sanctions Policy. Anti-Corruption Amneal complies with the U.S. Foreign Corrupt Practices Act and U.K Bribery Act throughout all our businesses globally, as well as individual countries’ anti-corruption laws where we do business. Amneal Global Anticorruption Policy prohibits giving anything of value, any ofer, payment, promise of payment, or authorization of the payment of any money, gifs, loans or other inducement, whether given directly or indirectly, to a government oficial or the employee of a private company in order to influence any act or decision of the oficial or employee to obtain or retain business or gain any regulatory or other commercial advantage. Amneal policy also prohibits the receipt of anything of value by an Amneal employee from suppliers, vendors or others who may seek thereby to influence any act or decision of the employee. Sept r 2 40