Code of Conduct

Anchored by our Code of Conduct (Code), we work at every level of the Company to educate our team members about the policies and standards to which we hold ourselves and about how to raise issues or concerns should they have them. Endo’s Code applies to all employees globally and defines how we interact with patients, healthcare providers, payors, suppliers, government officials, the healthcare community, shareholders and our colleagues. It is designed to enable team members to apply the principles of respect, trust and integrity to their day-to-day activities. All team members, full time contractors and select part time contractors and vendors are required to complete annual training on the tenets of the Code and certify that they will adhere to it.

The Code of Conduct calls on team members to:

The Code of Conduct was last amended effective April 20, 2021. The changes made were intended to better align the Code of Conduct with our updated vision, mission, values and strategic priorities and to update certain policies and standards. The areas addressed by the changes include anti-corruption and anti-bribery, data privacy, environmental responsibility, social media, workplace safety and maintaining an inclusive work environment. This summary is qualified in its entirety by reference to the full text of the Code of Conduct.

Several key policies and procedures within the Code include those specific to our Interactions with Health Care Professionals, Responsible Marketing and Promotion, Anti-Bribery and Corruption and Maintaining an Inclusive Work Environment Free of Discrimination, Harassment and Retaliation. Details on these policies and procedures can be found below and within our Code. To access our Code, see links below:

Endo's Code of Conduct (English)

Code de conduite d’Endo (French Canadian)

Endo வின் நடத்தை நெறிமுறைத்தொகுப்பு (Tamil – India)

Endo की आचार संहिता (Hindi – India)

Working with Healthcare Professionals

Endo educates healthcare professionals about our products, collaborates with them on research, relies on their expertise as advisers and trains them on the approved use of our products. Interactions with these professionals are governed by the respective country’s laws, regulations and standards. Our interactions must always reflect our commitment to integrity, compliance, accuracy and transparency, including adherence to our standards on prohibiting bribery and corruption. The research studies that Endo supports must have a legitimate scientific objective, be approved by the appropriate Endo scientific and medical reviewers and be conducted with scientific rigor. Additionally, all consulting arrangements with healthcare professionals must be reviewed and approved by appropriate management, medical and compliance reviewers, and payment must be at fair market value. We train all team members to work in a manner that is consistent with these applicable laws and standards.

For more details, please visit our Code.

Responsible Marketing and Promotion

Endo is committed to promoting our products based on the approved use of each product and the needs of the patient. We require truthful, on-label and ethical communications that will help healthcare professionals make informed and independent decisions about how they can use our products for their patients. Prior to the use or dissemination of any written or verbal advertising or promotional piece, the material must be approved and authorized by a promotional review committee of Company subject matter experts. These pieces must be on label, accurate, not misleading and comply with applicable legal, regulatory and local standards. Our team members complete annual training specific to this policy and our standard operating procedures that support it.

For more details, please visit our Code.

Anti-Bribery and Corruption

As regulators, payors or purchasers of our products, government officials are integral to our business. We may interact with government officials or entities through our research and development, regulatory, manufacturing and import/export activities. Our interactions with government officials therefore must comply with applicable anti-corruption laws. We prohibit any and all forms of bribery and corruption, including any such conduct by our third-party intermediaries. Team members are strictly prohibited to offer, promise, authorize or provide anything of value to any person—including government officials as well as those working in the private sector—to improperly influence them, win or retain business or otherwise gain an unfair business advantage. The solicitation and acceptance of bribes from any person is also prohibited. All Endo team members receive annual training on anti-corruption policies and procedures. Additionally, Endo provides training to relevant team members on due diligence and interactions with third-party representatives.

For more details please visit our Code.

Anti-Discrimination & Harassment

Endo is committed to providing equal employment opportunity and fair treatment to all applicants and employees on the basis of merit and prohibits discrimination based upon race, color, national origin, religion, ancestry, physical or mental disability, medical conditions, genetic information, marital status, pregnancy status, gender identity or expression, age, sexual orientation, veteran or military status or any other classification protected by applicable law. The Company is also committed to fair employment practices in its dealings with all employees, and therefore all team members are required to comply with all applicable labor and employment laws, including laws prohibiting discrimination and harassment. The Company strongly prohibits and will not tolerate harassment of employees by managers, supervisors, co-workers or non-employees. Similarly, the Company will not tolerate harassment by its employees of non-employees with whom the Company does business. Endo expects employees to treat each other with respect, dignity and sensitivity. Retaliation against an employee who has raised or reported in good faith, a violation of the Company’s policies against discrimination and harassment, or who engages in other protected activity, is strictly prohibited and will not be tolerated.

For more details, please visit our Code.