Acting with
Respect, Trust
and Integrity
The Endo Way
Our Code
of Conduct
A Message from
Our Chief Executive Officer
Dear Colleagues,
At Endo International plc and its subsidiaries (“Endo”), we are driven by our shared vision
of being a highly focused generics and specialty branded pharmaceutical company,
delivering quality medicines to patients in need through excellence in development,
manufacturing and commercialization. In order to achieve our aspiration, we must
maintain a competitive advantage in today’s marketplace by living our Core Values in a
manner that reflects our guiding principles of respect, trust and integrity—this is The
Endo Way.
Our reputation—as a company, as leaders and as individuals—depends on our approach
to ethics. Today’s compliance environment is highly dynamic and our approach to ethics
and compliance must be unwavering, proactive and strategic as regulatory and public
expectations continue to evolve.
Endo’s Code of Conduct (“our Code”) is designed to help you make the right decisions.
Sound, ethical decision-making is the foundation for how we do business. Acting with respect,
trust and integrity is critical to our strategy and is essential to the achievement of our vision.
The Endo Way enables us to earn and keep the trust and confidence of our healthcare
customers, patients, regulators and shareholders.
As an Endo employee, you are required to review our Code and adhere to all aspects of it in
order to ensure that we uphold our ethical responsibilities to our customers, the healthcare
community, patients, regulators, shareholders and the communities where we work and live.
Our Code reflects not only our guiding principles but also your personal accountability to
sustain our reputation for ethical behavior.
Sincerely,
President and Chief Executive Officer
Endo International plc
2 Our Code of Conduct
Paul Campanelli
A Message from
Endo’s Chief Compliance Officer
Dear Colleagues,
Today’s compliance environment is highly dynamic and our approach to ethics and
compliance must be unwavering, proactive and strategic as regulatory and public
expectations continue to evolve. Our reputation—as a company, as leaders and as
individuals—depends on our approach to ethics.
Endo’s Code of Conduct is designed to enable us to apply our guiding principles of
respect, trust and integrity to our day-to-day activities. Ethical decision-making based
on our Code of Conduct is the foundation of our success and results in a consistent
approach to compliance across our company.
What does this mean for you as an Endo employee, officer, director or agent?
First, take personal responsibility so that your actions and decisions are consistent with our
Code of Conduct and the Company policies applicable to your role. Second, foster and
promote a culture of ethical behavior in every aspect of your job—particularly when leading
or working in teams and collaborative settings. Third, know the rules and seek guidance if
you have questions about the right thing to do. Finally, speak up—respectfully and
appropriately—if you are aware of potential behavior that is inconsistent with our Code of
Conduct, values or Company policies.
Our Department’s mission is to maintain an effective corporate-wide compliance program
that enables us to achieve our strategic vision and business goals in an ethical, compliant
and sustainable manner. Our compliance program is founded on clear rules of business
conduct along with ongoing training, education and communication, and monitoring of our
program to assess and enhance its effectiveness. Endo is also committed to a culture of
openness with clear channels to report potential concerns in a confidential and anonymous
manner without fear of retaliation.
Our Code of Conduct is not intended to provide an exhaustive list of every policy you need
to know; rather it is an ethical compass to guide your daily activities. Beyond the Code,
there are numerous resources along with instructive Q&A’s to help you. Our Department
strives to provide leadership, resources and a solutions orientation based on trusted
partnerships and mutual respect.
No written code or policy can guarantee compliance with law or ethical decision-making.
Each of us has a personal responsibility to act with respect, trust and integrity: it is
everyone’s business and the Endo Way.
Sincerely,
Jennifer E. Dubas
Senior Vice President and Chief Compliance Officer
Ethics Hotline: 800-305-1563 | www.endo.ethicspoint.com 3
Table of Contents
Understanding Our Code
6 What is Expected of Everyone
7 What is Expected of Our Leaders
Using Your Ethical Compass and Seeking
Guidance
9 Resources for Seeking Guidance
Reporting Concerns
11 How to Raise a Concern
11 Anonymity and Confidentiality
12 Investigations of Possible Misconduct
12 Non-Retaliation Policy
12 Disciplinary Actions
12 Ethics Hotline
Endo and the Healthcare Community
15 Good Operating Practices
16 Monitoring the Safety, Performance and Quality
of Our Products
17 Promoting Our Products
18 Interacting with Healthcare Professionals and
Healthcare Providers
19 Government Inspections and Requests
Our Customers, Suppliers and Government
Officials
22 Competition and Antitrust
23 Anti-Corruption and Anti-Bribery
24 Pricing and Billing Information
24 Competitive Intelligence
25 Political Activities and Political Donations
26 Trade Restrictions
Our Workplace and Our Communities
29 Our Work Environment
30 Protecting Employee Safety and the Environment
31 Supporting the Community
Our Company and Our Shareholders
34 Conflicts of Interest
35 Insider Trading
36 Intellectual Property and Confidential Information
37 Privacy
38 Financial Integrity
39 Use of Company Systems and Resources
39 Company Records and Information Management
40 Corporate Affairs and Investor and Media
Relations
Compliance at Endo
42 Our Compliance Program
The Endo Code of Conduct is not a contract of employment. Endo reserves the right to modify any aspect of its compliance
program, including this Code of Conduct, without prior notice. If there is a conflict between this Code and a Company policy,
the policy currently in effect shall govern.
4 Our Code of Conduct
Understanding
Our Code
Each of us influences our company’s
reputation. Our Code helps us maintain and
strengthen our reputation for integrity.
Understanding Our Code
To help us act with respect, trust and
integrity, Endo’s Code of Conduct defines
how we interact with patients, healthcare
providers, payors, suppliers, government
officials, the healthcare community,
shareholders and each other. This Code
applies to every person conducting
business for Endo and to all Endo locations,
affiliates and subsidiaries. Due to local law
in some countries, some provisions may
be supplemented by policies or standards
to address local requirements. When Endo
standards differ from local requirements,
always follow the higher standard.
What is Expected of Everyone
Each of us is individually accountable for
acting in accordance with this Code. All
officers and employees must certify, in
writing or electronically, that they have
reviewed, read, understand, and shall
abide by this Code. Any waiver for a person
covered by the Code must be submitted
to and approved by the Chief Compliance
Officer.
✓ The Endo Way
• Act with honesty, fairness, integrity and
personal accountability to protect our
reputation
• Never compromise your integrity for the
sake of “making the numbers” or due to
pressure from a supervisor
• Respect fellow staff, government
officials, business partners, competitors,
customers and patients
• Know and follow the rules and seek
guidance
• Sustain a culture where ethical conduct
is expected, recognized and valued
• Report known or suspected violations of
this Code
• Cooperate with investigations—always be
forthcoming and tell the truth
• No form of retaliation or intimidation
against an employee who makes a good-
faith report of a suspected violation
or participates in good faith in any
investigation of a suspected violation will
be tolerated
6 Our Code of Conduct
What is Expected of Our Leaders
As a leader, you serve as an ethical role
model and are held to a higher standard.
This means proactively identifying
questionable conduct, preventing problems
before they occur and setting the right
tone with your reports and across the
Company. You are also accountable for
undertaking reasonable efforts to ensure
that contractors or agents working under
your management control adhere to the
Code.
✓ The Endo Way
• Foster a culture that focuses on
integrity, ethics and compliance,
collaboration, quality and patient
safety as expected behaviors
• Guide your teams and reinforce the
importance of our Code, our Vision,
Core Values and Company policies
along with timely completion of ethics
and compliance training
• Partner with compliance leaders
• Take reasonable steps to make sure that
vendors and consultants act in a manner
consistent with this Code
• Proactively prevent and respond to ethics
and compliance issues in a way that
always reinforces the appropriateness of
raising issues
• Take appropriate disciplinary actions
in consultation with human resources,
compliance leaders and legal contacts
3
Ethics Hotline: 800-305-1563 | www.endo.ethicspoint.com 7
Using Your
Ethical Compass
and Seeking
Guidance
The right course of action is not always
obvious. Reputations are maintained
and built by everyday decisions.
Using Your Ethical Compass
and Seeking Guidance
Our Code of Conduct is not a substitute for
understanding and following the policies
applicable to your role. Although the Code
cannot anticipate every situation, it can and
should serve as an ethical compass. If you
have any doubts about a potential course of
action, ask yourself the following questions:
• Is it legal?
• Is it ethical and consistent with our
Core Values?
• Is it consistent with our Code of
Conduct?
• Am I being truthful and honest?
• Will it reflect positively on our reputation
for integrity?
• Would I feel comfortable if it was
reported in the news or to someone
I respect?
If you still have questions, always seek
additional guidance. You are not alone when
faced with a tough ethical decision. If the
answer to any of these questions is “no,” do
not do it. It is never permissible to ignore
our Code of Conduct to achieve a business
objective.
Resources for Seeking Guidance
• Your Manager
• Business Unit Compliance Leader
• Corporate Compliance and Business
Practices Department
• Human Resources
• Legal Department
• Ethics Hotline
Ethics Hotline: 800-305-1563 | www.endo.ethicspoint.com 9
I have questions about whether a proposed business plan complies
with Company policy but worry that my manager will assume I do
not know how to perform my job. What should I do?
Endo encourages and expects employees to raise questions. Managers
are expected to foster an environment where everyone feels comfortable
doing so and are likely the best people to speak with first. Your business
compliance leader, human resource or legal contact will also be in a
position to provide guidance. You may also raise the issue through Endo’s
Ethics Hotline. If you have a question, it’s your responsibility and Endo’s
expectation that you’ll ask.
Reporting Concerns
Raising an integrity concern protects our
company and our reputation.
Reporting Concerns
You play an important role in helping us
meet the standards reflected in our Code
of Conduct. When you raise an issue, we
can look into the matter, take timely and
appropriate action and make corrections,
if necessary. If you observe or have
knowledge of potentially inappropriate
conduct, you have an obligation to report
your concerns. Endo has established
procedures for handling reported concerns.
✓ The Endo Way
• Promptly raise concerns about a
potential violation of law, Company
policies or our Code of Conduct
• Foster an “open door” policy and
maintain awareness of the variety of
channels to raise and report concerns
• If a concern you raise is not resolved,
raise it through another channel
• Fully cooperate with Endo investigations
and always be forthright and honest
How to Raise a Concern
Endo offers several channels to raise
concerns. You should use the channel that
is most comfortable to you. As a general
matter, your supervisor or manager may
be in the best position to address an issue.
However, that is not your only option.
Potential channels to report a concern are:
• Direct Management or Senior
Management
• Business Compliance Leaders
• Corporate Compliance and Business
Practices Department
• Business Legal Contacts
• Business Human Resource Leaders
Endo also has in place an Ethics Hotline
where reports can be made at any time
by phone or online. All reports, whether
submitted by phone or online, will be
issued a reference number. You may use
that reference number to provide further
information or check the status of an
investigation by phone or online at
www.endo.ethicspoint.com , regardless of
how you originally used the hotline. You
should note that investigations take time
and our ability to share information may
be limited.
Anonymity and Confidentiality
Where permitted by local laws, you may
use the Ethics Hotline to anonymously
report known or suspected issues or ask
a question. Some countries prohibit or
discourage anonymous reporting or restrict
the types of information that may be
reported. If you use the Ethics Hotline from
one of those countries, you will be advised
of any specific reporting restrictions. Toll-
free international numbers are available
at www.endo.ethicspoint.com for every
country in which Endo has employees.
The information you report will be treated
as confidentially as possible. Your report
will be shared only with those who need
to know about it to answer your question
or toinvestigate the matter. Should you
choose to identify yourself, Endo will
make every reasonable effort to keep
your identity confidential. while at the
same time meeting its obligation to fairly
investigate the matter. In some instances,
Endo may be required to reveal your
identity, if known.
Ethics Hotline: 800-305-1563 | www.endo.ethicspoint.com 11
Ethics Hotline
800-305-1563
Visit
www.endo.ethicspoint.com
to report a concern
or access toll-free
international numbers
Investigations of Possible
Misconduct
Endo takes reports of alleged misconduct
very seriously and will investigate them to
determine if any law, Company policy or
aspect of our Code of Conduct may have
been violated.
Non-Retaliation Policy
No form of retaliation or intimidation
against an employee who makes a good-
faith report of a suspected violation
or participates in good faith in any
investigation of a suspected violation
will be tolerated. Employees who engage
in retaliation or intimidation will be
subject to disciplinary action, up to and
including termination.
Endo reserves the right to discipline anyone
who knowingly makes a false accusation,
provides false information about the
Company or has acted improperly.
Disciplinary Actions
Any employee who violates this Code,
Company policy or applicable laws
may be subject to disciplinary action,
up to and including termination.
Misconduct may include violations
of this Code and Company policies,
failure to raise a known or potential
issue, not cooperating with an
investigation or intimidating or engaging
in retaliation against an employee who
raises a potential issue or provides
information during an investigation.
12 Our Code of Conduct
One of my reports asked me to discuss a potential issue. How
should I approach him?
Your reaction is extremely important. Allow adequate time to
discuss the potential concern in an appropriate location. Listen
as much as possible and do not be defensive. You should not feel
required to give an immediate answer. Reassure him that the
Company takes reports of misconduct very seriously. Depending
on the potential concern, you may need to involve HR, your
management, business compliance leader or legal contact. Treat
an employee who raises an issue with respect and do not retaliate
against or intimidate the employee in any manner.
Endo and the
Healthcare
Community
Patients, healthcare providers and
healthcare regulators expect safe,
effective and high quality products from
trusted partners who act with integrity.
Endo and the Healthcare
Community
We act responsibly, lawfully and with
integrity in our relationships with members
of the healthcare community—patients,
patient groups, healthcare providers and
healthcare regulators. Maintaining these
principles in our daily activities is critical
to sustaining trust in our products and
fulfilling our vision and mission.
✓ The Endo Way
• Adopt good operating and quality
principles throughout our research,
development, manufacturing and
distribution activities, always focusing on
patients
• Communicate with healthcare providers,
patients and the public in a fair and
balanced manner
• Interact with healthcare providers
ethically and in accordance with
applicable laws and regulations when
promoting or providing information
about our products
• Continuously monitor the safety,
performance and quality of our products
• Promote transparency and cooperate
with healthcare regulators by always
providing truthful and complete
information in a manner that facilitates
trust and partnership
14 Our Code of Conduct
Good Operating Practices
Maintaining the quality of our products is
critical to patient safety and to our success.
Quality is what patients and the healthcare
community expect of us. We meet these
expectations by embedding quality
principles into our operational activities
and by adhering to applicable laws and
practices. Endo is committed to continuous
quality and process improvement across
our business segments.
Special rules and regulations apply to
the handling, storage and transfer of
controlled substances. We must strictly
comply with these requirements and
our policies and procedures related to
controlled substances. If you have any
knowledge or suspicion about the improper
handling, transfer, loss or diversion of a
controlled substance, you are required to
immediately report it to your manager or
the Ethics Hotline.
Failure to report suspected diversion or
a theft of our products is a violation of
this Code and may subject an employee
to disciplinary action, up to and including
termination.
✓ The Endo Way
• Maintain in each business unit written
policies and procedures that define our
standards for delivering high-quality
products
• Complete training in a timely manner
• Maintain accurate and complete records
and conduct routine audits
• Be diligent in identifying and preventing
practices that could impact the quality of
our products
• Report potential instances of
non-compliance
• Promote continuous process
improvement
Ethics Hotline: 800-305-1563 | www.endo.ethicspoint.com 15
We are behind schedule and under pressure to increase
production. May we slightly modify a few manufacturing steps
to speed things up?
Although we strive to continuously make our manufacturing
processes more efficient, our commitment to quality is foremost.
Always follow our quality standards and approval processes when
considering a modification to a manufacturing process. Discuss
your potential process improvement with your management and
site quality leader to assess if it is feasible and consistent with our
quality standards.
Monitoring the Safety,
Performance and Quality of
Our Products
Patient health and safety are top
priorities. Maintaining the quality of our
products and the continued monitoring
of their performance is paramount to
protecting the safety of patients. We
have a responsibility to detect and report
adverse events and quality complaints
associated with our products, including
unfavorable side effects, dosing errors,
misuse, malfunctions and concerns about
performance or efficacy of a product.
Endo operates across multiple industries
with timing and reporting procedures that
vary. We conduct periodic reviews and
analyses of safety information and always
take responsible and appropriate actions to
improve the safety profile of our products.
✓ The Endo Way
• Report all adverse events and complaints
that you become aware of for any Endo
product
• Follow the instructions that are provided
to you and are standard in your business
unit for reporting safety information
• Provide prompt notification, in
accordance with the requirements of
Company policy, to your business unit of
any potential safety issue or incident
• If you are unsure whether an adverse
event has occurred or whether an
incident is reportable, report it through
the designated channels and allow our
experts to make that determination
16 Our Code of Conduct
While on vacation, a fellow traveler mentioned that he felt nauseous after
taking one of our products. Do I have to report this conversation?
Yes. Although our product may not have caused an adverse event, those qualified
and responsible for such determinations should be notified and make the
decision. Report the conversation for appropriate review and analysis so that any
potential reporting requirements are met and we fulfill our commitment to patient
health and safety.
Promoting Our Products
Endo is committed to promoting its
products based on patient needs and the
merits of each product in a transparent,
legal and accurate manner.
Our interactions with healthcare
professionals should be focused on
educating them about our products,
and supporting their medical education
and training needs to lead to improved
patient care. We encourage truthful and
ethical communications that will help
healthcare professionals make informed
and independent decisions about how they
can best use our products on label for their
patients.
The ideal location for providing educational
information about Endo products is in a
physician or health care provider’s office, a
hospital or other clinical setting. Local law
or industry codes may allow for certain
discussions outside of those settings in
specific circumstances. Always follow the
Company policy applicable to your
business unit.
If you have any questions, contact your
business unit compliance leader or the
Corporate Compliance and Business
Practices Department.
✓ The Endo Way
• Only use promotional materials and
communications that have been
approved by appropriate disciplines, are
on label, accurate, not misleading and
comply with applicable legal, regulatory
and local standards
• Do not promote the use of any product
beyond its approved labeling and
authorization
• Promotional materials must be
previously approved, consistent with
approved labeling information and be
supported, as appropriate, by scientific
evidence
• Provide fair balance by presenting the
full picture of our products, including a
summary of all safety information
• Do not mischaracterize or make unfair
comments about competitors’ products
A doctor on my call plan mentioned that her colleague used one of our
products with good results for patients not suffering from the conditions
indicated in our label. She asked for information from scientific literature
about off-label uses. I am aware of recent studies from an industry
conference I attended. Can I share that information?
No. Your obligation is to refer her to our medical information contacts who are
able to provide complete and accurate scientific information in a manner that is
consistent with Company policy. In accordance with Company policy, provide her
with the necessary information to complete documentation for an unsolicited
request for information or provide the number to directly call our medical
information staff. When promoting a product, only discuss on-label information.
Ethics Hotline: 800-305-1563 | www.endo.ethicspoint.com 17
Interacting with Healthcare
Professionals and Healthcare
Providers
Endo educates healthcare professionals
and healthcare providers about our
products, collaborates on research,
relies on their expertise as advisers and
trains them on the use of our products.
Our interactions must always reflect our
commitment to integrity, compliance,
accuracy and Transparency, including
adherence to our standards on
prohibiting bribery and corruption.
Endo also promotes scientific integrity
and does not allow business pressures
to influence in any way this valuable
collaboration that advances scientific
and medical understanding, including
the appropriate use of our products, the
management of diseases and patient care.
✓ The Endo Way
• Engage healthcare professionals only
when there is a bona fide need and
always pay a fair fee consistent with our
Fair Market Value policies and applicable
local law whenever a fee is to be paid
• Never attempt to buy business or
provide anything of value to influence
any healthcare provider’s judgment to
choose an Endo product nor create any
misperception that Endo is doing so
• Provide appropriate instruction,
education and training on the safe and
effective use of our products
• Maintain transparency regarding all
your interactions with healthcare
professionals and providers, institutions
and others in the healthcare community
• Do not accept, pay for, or otherwise
promote or encourage patient referrals in
exchange, or as an improper inducement
for the purchase, lease, recommendation
or use of any Endo product
18 Our Code of Conduct
An approved physician speaker is presenting at an Endo sponsored educational
program for patients who may benefit from using one of our products. Can the
physician customize the handouts and revise our approved slides?
No. Our educational and promotional materials are developed through a rigorous
review process. It is never permissible to use unapproved materials or modify
approved materials or visual aids.
We are having a hard time introducing local physicians to one of our recently
approved products. One recommendation is to conduct a study and enroll local
physicians as investigators. This will allow them to get acquainted with our
product and enhance our efforts to introduce it. Is this ok?
No. Studies must have scientific merit, may only be conducted to serve a scientific
purpose and never should be intended to “seed” the market or promote a product.
Government Inspections and
Requests
We operate in a complex and dynamic
regulatory environment. Our facilities
and activities are routinely inspected by
healthcare and other regulators around
the world. At all times, Endo cooperates
with regulatory authorities. Effective
engagement with regulators is critical to
our reputation and our ability to deliver
safe, effective and high quality products.
In the event of a non-routine request for
information or a facility visit, the Legal
Department must be notified immediately.
The Legal Department represents
the Company on all legal matters and
determines the appropriate information
to be provided and will facilitate our
cooperation with investigative authorities.
✓ The Endo Way
• Cooperate with and be courteous to
government inspectors and coordinate
with our quality, safety and regulatory
experts in response to regulatory
inspections and requests
• Always provide regulators with honest,
accurate, responsive and timely
information
• Be familiar with your site’s procedures
for complying with a request to access
the premises
• Contact the Legal Department
immediately in the event of a non-routine
or legal inquiry, such as a subpoena
Ethics Hotline: 800-305-1563 | www.endo.ethicspoint.com 19
How should I respond to an inspector’s question about a process
with which I am not familiar?
Be truthful and upfront. It is okay to state, “I don’t have an answer”
and tell the inspector that you will get the answer as soon as
possible. Never guess, provide incomplete information or answer
questions that you do not fully understand.
Our Customers,
Suppliers and
Government Officials
We act with integrity in our
dealings with customers, suppliers
and government officials.
Our Customers, Suppliers
and Government Officials
Endo interacts with many types of
individuals and entities including
healthcare professionals, hospitals,
governments, regulatory authorities,
business partners, customers, suppliers
and vendors. These interactions may
arise in our sales and marketing, research
and development, and manufacturing
operations, as well as our import/export
activities. In all business dealings, Endo
will be fair and honest and will comply with
applicable law and Company policies.
✓ The Endo Way
• Adhere to competition and antitrust laws
in the countries where we operate
• Comply with anti-bribery laws and do
not offer or make illegal payments to
government officials or business partners
either directly or indirectly through
intermediaries
• Provide transparent and accurate pricing
information to governments, private
payors and healthcare providers
• Gather competitive intelligence in an
ethical and lawful manner
• Conduct political activity responsibly and
in compliance with applicable law
• Follow global trade laws
Ethics Hotline: 800-305-1563 | www.endo.ethicspoint.com 21
Competition and Antitrust
Many countries have fair competition
l a w s . These laws generally prohibit anti-
competitive practices, such as price-fixing,
boycotting suppliers or customers and the
exchange of information that may harm
competition.
Mergers, acquisitions and other types of
transactions may require prior review or
even clearance. These laws are complex
and vary by country, so it is critical that you
consult with the Legal Department.
✓ The Endo Way
• Do not discuss, exchange information or
enter into agreements with competitors
about prices, strategic plans, terms or
conditions of sale, production or
distribution, allocation of products,
territories, markets or customers, and do
not use third parties as conduits for any
such discussions discussions, information
exchanges, or agreements
• Do not discuss or plan joint behavior
(such as boycotts) towards customers,
suppliers or competitors
• Do not make false or disparaging
comments about competitors or their
products or steal or misuse competitor
trade secrets
• Do not manipulate a competitive bidding
process
22 Our Code of Conduct
I am attending a local industry association meeting and
several competitors are discussing their marketing and pricing
strategies. What should I do?
Although industry meetings have legitimate purposes, they create
risks for anti-competitive discussions. A group of competitors
discussing issues of mutual concern could cross a line into an anti-
competitive topic. If you find yourself in a situation where a topic
seems inappropriate, leave the discussion immediately and make it
clear to those present that you are leaving due to the nature of the
conversation. You should also report the issue to your legal contact
as soon as possible.
In my country, it is customary to provide a healthcare provider
who uses one of our new products with a scientific incentive
payment. Are such payments permissible under our Code of
Conduct?
No. Any form of payment used to exert improper influence over
healthcare professionals is prohibited, regardless of the customary
practices in the country. In many countries, healthcare professionals
are considered government officials and the payment could violate
the FCPA or similar laws. Remember, when Endo’s standards differ
from local requirements always follow the higher standards.
Anti-Corruption and Anti-
Bribery
As regulators, payors or purchasers of
our products, government officials are
integral to our business. Healthcare
professionals who are public employees
may be considered government officials in
many countries. Through our research and
development, regulatory, manufacturing
and import/export activities, we may
interact with government officials or
entities that are state owned. Most
countries forbid making, offering or
promising anything of value either directly
or indirectly to a government official when
the exchange is intended to influence an
official act or a decision to obtain or retain
an unfair business advantage. The U.S.
Foreign Corrupt Practices Act (“FCPA”) and
similar laws in other countries govern our
interactions with government officials.
Many countries also have laws aimed at
prohibiting commercial bribery. The U.S.
Federal Anti-Kickback statute prohibits
inducing someone to recommend or
purchase a healthcare product or service
covered by the U.S. federal healthcare
program. The intent of this law is to prohibit
the impermissible influence of money or
things of value in the selection of products
or services that are reimbursed by the U.S.
federal healthcare program.
Payments, gifts or services should not
be given to government employees or
healthcare providers that are intended to or
appear to influence their actions. In short,
Endo does not permit bribery of any kind.
✓ The Endo Way
• Do not make, offer or promise anything
of value, including cash, services,
gifts, entertainment or other business
courtesies, in an attempt to influence
a person’s actions, obtain a regulatory
advantage, influence formulary status or
enhance Endo’s commercial interests
• Business courtesies and gifts offered
or received must be of modest value by
local standards and may only be offered
or received under circumstances that
comply with Company policies and local
law and industry codes
• Be aware that in countries with
nationalized or public healthcare
systems, healthcare professionals may
be considered government officials
• Adhere to Company policies when
interacting with government officials
and be conscious of whether you are
interacting directly or indirectly (such as
through a distributor or other third party)
with government officials
• Maintain your knowledge and complete
training on Company policies and global
and local anti-bribery laws
Ethics Hotline: 800-305-1563 | www.endo.ethicspoint.com 23
I am hiring a researcher from
a competitor. What questions
may I ask about his or her prior
employer?
Never ask a former employee of a
competitor about any information
that the person is under a legal
obligation not to reveal. This
would include trade secrets and
other confidential information.
Consult with the Legal Department
about necessary precautions to
avoid improperly soliciting such
information.
Pricing and Billing Information
The procedures for obtaining payments
and reimbursements from government and
private insurers are complex.
We have a legal and ethical responsibility
to provide transparent pricing information
to governments, private payors and
healthcare providers. The submission
of inaccurate pricing information or
fraudulent claims to a government could
subject our Company to substantial fines
and penalties.
✓ The Endo Way
• Always provide accurate and complete
information to government and private
payors
• Adhere to Company policies on
obtaining approval for, documenting and
communicating lawful discounts, rebates
or administrative fees
• Utilize accurate and complete
information about billing, coverage,
reimbursement and coding that adheres
to local law and industry codes
Competitive Intelligence
Endo employees are encouraged to
appropriately collect, share and use
information about our competitors
(“competitive intelligence”). However,
just as we value our own non-public
information, we respect the non-public
nature of certain information about our
competitors. We use only ethical and legal
means to gather competitive intelligence.
It is always acceptable to gather
competitive intelligence through publicly
available information. Publicly available
filings, presentations, news, journal articles
and publications are legitimate sources
of competitive intelligence. You may also
ask third parties about competitors or
accept competitive intelligence offered
by third parties as long as there is no
reason to believe the third party is under
a contractual or legal obligation to not
disclose the information or has gathered
the information illegally or unethically.
✓ The Endo Way
• Never attempt to or ask a third party
to acquire information through
unethical or unlawful means, such as
misrepresentation, deception, theft,
spying, bribery or by breaching a
nondisclosure agreement
• If there is any indication that information
you obtained was not lawfully or ethically
received or gathered, refuse to accept it
• If you receive competitive intelligence
anonymously or information that is
marked confidential, do not review
it and contact the Legal Department
immediately
24 Our Code of Conduct
A friend is running for local office
and I would like to help him with
his campaign. Is this allowed?
Yes. Your personal political activities
are your own—not Endo’s. Just make
sure not to use Company resources
including Company time, e-mail or
the Company’s name to advance
the campaign.
Political Activities and Political
Donations
Endo educates policymakers through well-
informed policy positions on issues that
impact our business. Our participation in
the political process is appropriate, ethical
and adheres to applicable laws.
Endo recognizes and encourages the right
of our employees to participate in the
political process as individuals. However,
you may only participate on your own time
and at your own expense. Company funds,
facilities or assets may not be used for
personal political activities.
Many countries regulate the political
activities of corporations. You should
consult with Government Affairs regarding
potential political activities. In the U.S., gifts
of any value including meals or products
should not be provided to Members of the
U.S. Congress, their staffs or state and
other government officials. Only certain
individuals in Government Affairs may
engage in lobbying activities on behalf of
the Company.
Although prohibited under U.S. law from
making payments to political parties,
candidates or organizations, Endo is
permitted to and has established a Political
Action Committee (“Endo PAC”) in the
U.S. Contributions to the Endo PAC are
entirely voluntary. No employee will be
favored or disfavored based on his or her
contributions.
✓ The Endo Way
• No corporate contributions for a
candidate for any office should be made
by or on behalf of Endo outside of the
Government Affairs Department
• Consult with Government Affairs prior to
contacting public officials about U.S. and
international restrictions on corporate
political activities
• Do not use Endo funds or other assets,
such as telephones, e-mail accounts,
conference rooms or stationary to assist
a candidate, public official or political
committee
• In personal civic affairs, clearly indicate
that your views and actions are your own,
not Endo’s
Ethics Hotline: 800-305-1563 | www.endo.ethicspoint.com 25
Trade Restrictions
Most countries regulate the flow of
materials, information, services and funds
into and out of their territories. We must
comply with licensing requirements,
boycotts, embargoes and other trade
restrictions that have been approved by
recognized national and international
authorities. Such requirements may
relate to, among other items, chemicals,
biological materials, equipment, finished
products and data/technology.
Endo will not engage in business with
countries or parties subject to such trade
sanctions unless lawful and properly
authorized. We also comply with export
licensing, clearance requirements and
customs laws for the countries in which we
do business. Endo will provide accurate and
truthful information about our products
and other items (such as pharmaceutical
ingredients) to customs and other relevant
authorities. Endo will not cooperate with
any requests to participate in international
boycotts as prohibited by law.
✓ The Endo Way
• Maintain and complete accurate import
declarations and review the export
classification of materials prior to export
to determine if a special authorization is
required
• Know your customer and supplier and
screen your transactions against all
applicable rules that prohibit improperly
dealing with sanctioned countries,
persons or entities
• Do not cooperate with illegal restrictive
trade practice or boycotts
• If your responsibilities involve
international dealings, maintain your
knowledge of and compliance with
current import/export controls,
licensing requirements and trade
restrictions which change frequently
due to political and security threats
26 Our Code of Conduct
I am trying to clear a product through customs. The local customs agent is
asking for an additional signature to satisfy local requirements. I know it is
customary to offer something to “speed things up.” Time is of the essence. If
local customs is not cleared quickly, patients may be adversely impacted by a
supply shortage. What should I do?
First, understand the current import/export requirements for the country involved.
Determine if further authorizations are in fact required by local law. Never provide
gratuities to any officials to facilitate preferential treatment, regardless of the
unwritten law of the land. Seek the advice of your manager or the Legal Department
to identify legally acceptable ways to secure a timely release of our product.
Our Workplace
and Our Communities
Our workplace environment and
commitment to our communities reflects
our values. Through our giving, we also
strive to improve treatment outcomes.
Our Workplace
and Our Communities
Endo seeks to create a productive work
environment that reflects our values and
attracts diverse and talented employees.
This involves striving to maintain a safe
workplace and to preserve our environment
and always adhering to environmental
and safety laws. As a Company, we strive
to improve treatment outcomes and are
committed to appropriate partnerships
with third parties that further these goals.
We also support the global and local
communities where we work and live.
✓ The Endo Way
• Maintain fair employment practices that
comply with applicable law and foster a
culture of respect, trust and integrity that
facilitates productivity, collaboration and
values diversity
• Protect the health and safety of our
employees in accordance with Company
policy and law
• Strive to act in an environmentally
responsible way and comply with
environmental laws
• Positively impact our communities
through active engagement and support
28 Our Code of Conduct
Our Work Environment
Each of us is responsible for maintaining
a work environment that is free from
unlawful harassment in any form and
recognizes and values a diverse
workforce. Our employees should exhibit
the highest standards of professionalism
and integrity. Any behavior that
constitutes unlawful harassment
or discrimination will not be permitted.
Endo recruits, hires, trains and promotes
our employees without regard to their
race, color, religion, gender, age, national
origin, citizenship, marital status, sexual
orientation, gender identity, genetic
information, disability, veteran status or
other protected characteristic.
✓ The Endo Way
• Discourage and report comments or
physical acts that are inappropriate,
offensive or derogatory to others
• Jokes, slurs and other remarks about
characteristics that are protected by law,
or that are of a sexual nature, are not
appropriate
• Remarks or physical conduct that
interfere with another person’s work
or creates an intimidating, hostile or
offensive work environment are not
tolerated
• Follow Company policies and applicable
laws prohibiting unlawful discrimination
Ethics Hotline: 800-305-1563 | www.endo.ethicspoint.com 29
One of my colleagues makes seemingly innocent and
complimentary comments about the appearance of a peer. Is it
appropriate?
Frequent comments may rise to the level of creating a hostile
work environment. An occasional general comment such as “I like
your new haircut” is generally acceptable. Much depends on the
specific nature of the comments, their frequency and the overall
environment. If in doubt about the appropriateness of a comment,
do not make it. Intimidating, hostile or offensive comments should be
reported to your manager, Human Resources, Legal or the Ethics
Hotline.
Protecting Employee Safety and
the Environment
Endo employees are one of our most
valuable assets. We have a responsibility
to each other to maintain the safety
and security of our work areas. Endo
is committed to maintaining a work
environment free from the influence of any
substance that could impair our ability to
safely and professionally execute our job
responsibilities.
Violence in the workplace will not be
tolerated.
Endo will strive to act in an environmentally
responsible way. All employees are
responsible for compliance with applicable
legal and regulatory requirements on
environment matters.
✓ The Endo Way
• Participate in safety training and adhere
to Company safety and security policies
• Promptly report safety concerns or
threatening or violent behavior
• Never use alcohol, illegal drugs,
controlled substances or medication
in a way that might harm your ability
to perform Endo business safely and
successfully
• Selling, purchasing, possessing or using
any illegal drug on Endo property or while
conducting Endo business is prohibited
• Do not engage in violent or physically
threatening conduct while taking part in
any work-related activity
• It is prohibited to possess firearms, weapons,
firework or explosives on or near areas of Company
property
• Comply with all applicable environmental
laws and report any environment
incidents
• Take appropriate measures to reduce
or eliminate the creation of waste and
conserve resources
30 Our Code of Conduct
Supporting the Community
Endo is committed to supporting initiatives
that improve our communities, provide
better access to care for patients and
improve treatment outcomes. We support
appropriate education for healthcare
professionals and research that will
advance scientific knowledge about our
products and develop new products.
Our grants, donations and charitable
contributions take the form of healthcare
partnerships, community partnerships
and disaster relief, as well as support for
non-profits and global initiatives. We fund
high-quality, educationally-appropriate
and timely medical education. Endo-
supported education must provide fair,
balanced and independent content to
healthcare professionals and be delivered
in accordance with applicable local law and
relevant industry standards.
✓ The Endo Way
• Support non-profit organizations
that facilitate involvement with and
assistance to our local communities
• Support disaster relief as well as non-
profit and global initiatives in a manner
that is consistent with our mission and
policies
• Foster partnerships through the support
of local or regional public health policy
efforts to protect and improve the quality
of care for patients
• Support medical education and clinical
training to help advance improvements
in patient care in Endo’s areas of
therapeutic interest consistent with
industry standards and Company policies
• Support independent investigator
sponsored research that may advance
clinical care, medical and scientific
knowledge about our products and lead
to new medical therapies consistent with
industry standards and Company policy
Ethics Hotline: 800-305-1563 | www.endo.ethicspoint.com 31
One of the physicians in my region has been telling me that he would like
the opportunity to conduct an investigator sponsored study with one of our
products. He doesn’t know what that could be and he asked me to find out
what the company has been looking into and might be inclined to approve. As
a sales person I am aware of our brand team’s strategy and could easily give
him some ideas. Should I do it?
No. Investigator sponsored research should be based on ideas originated by the
investigator him/herself and in your role as a salesperson, your responsibility is
only to direct the physician to an approved Endo grants portal for information.
Can an Endo employee provide input on the content of a Continuing Medical
Education (“CME”) event or program funded by an Endo grant?
No. All CME activities funded through Endo grants are independent and must not
be influenced by Endo in any way.
Our Company
and Our Shareholders
We are responsible for conducting our
operations in the best interest of our Company
and making ethical business decisions that
create value for shareholders.
Our Company
and Our Shareholders
Endo will operate in the best interests
of the Company and our shareholders,
be forthright about our operations and
performance and exercise care in the use
and protection of our assets and resources.
✓ The Endo Way
• Avoid conflicts of interest
• Do not disclose inside information and
never trade public securities based on
inside information
• Protect patents, trademarks, trade
secrets and other intellectual property
and safeguard confidential information
• Respect privacy and appropriately
safeguard personal information,
including personal health information
• Maintain and retain accurate books and
records consistent with applicable law
and Company policy
• Maintain an effective system of controls
over financial reporting
• Use Company resources and systems
appropriately
Ethics Hotline: 800-305-1563 | www.endo.ethicspoint.com 33
My neighbor who is a close personal friend owns a company that
supplies certain materials to Endo. Is this a conflict of interest?
Although not explicitly prohibited, it would be appropriate to disclose
this to your manager. If appropriate, your manager will work with the
Legal Department and your compliance leader to find the best
solution. In no way should you try to influence our business with
your friend’s company.
How do I understand if an offer of a meal or entertainment from
a supplier is appropriate? I did not solicit the invitation, which I
know would be impermissible.
You may accept infrequent and occasional meals and entertainment
if the supplier attends and the costs are modest by local custom.
Ordinary business meals and attendance at local sporting events are
generally acceptable. An invitation to an out of town or a premium
event would not be appropriate. Even a gift of modest value could
create an appearance of a conflict of interest, such as if the supplier
may be bidding on Endo business. If in doubt, discuss the issue with
your business compliance leader or manager. It is always preferable
to pay the fair market value of a meal or ticket to avoid any potential
appearance of a conflict of interest.
Conflicts of Interest
Nothing you do in your professional life or
during your free time should conflict with
your responsibilities to Endo. A conflict
of interest arises when the prospect of
personal gain may improperly influence
your ability to conduct Endo’s business.
Examples may include using your position
for personal gain, outside employment
interfering or competing with your Endo
employment, referral of Endo business
to a firm with which you have a personal
relationship or soliciting or receiving
gratuities from suppliers or vendors.
Endo deals with suppliers and others doing
business with us in a fair and objective
manner without favor or preference. A
conflict of interest or potential conflict of
interest may often be resolved or avoided if
disclosed and approved. In other instances,
disclosure may not be sufficient. It is
important that you use available resources
to discuss and resolve any potential
conflicts of interest.
✓ The Endo Way
• Disclose to your manager, legal contact
or compliance leader outside activities
and employment relationships, financial
interests or relationships that may
present an actual or potential conflict
• Obtain approval from your legal contact
or compliance leader before accepting
an officer or director position with an
outside business or serving on a non-
profit board
• Do not seek or accept, directly or
indirectly, any payments, fees, loans
or services from any person or firm as
a condition for their doing business
with Endo
• Do not seek or solicit any gifts,
entertainment or benefits from those
doing business or seeking to do business
with Endo
• Do not accept gifts, entertainment or
benefits greater than modest value
by local standards from those doing
business or seeking to do business with
Endo and avoid any perception of a
potential conflict of interest
• Do not use or misuse Endo resources,
intellectual property or facilities for
personal gain
• Do not allow personal relationships to
conflict with your Endo responsibilities
• Avoid hiring, promoting or directly
supervising a family member or
close friend
34 Our Code of Conduct
I recently learned that Endo
i s actively negotiating a joint
venture with a publicly-
traded company that I have
been researching as a
potential Investment. May I
still purchase stock in this
company?
No. Trading on material non-
public information is illegal. The
prohibition applies to trading in
the stock of Endo or the other
company, even if you have an
unrelated reason for trading
the stock.
Insider Trading
Many countries have laws regarding insider
trading. As an Endo employee, you may
learn of inside information—information
that is not known to the general public and
that an average investor might consider
important when deciding whether to buy,
sell or hold securities. You may not disclose
this information to others. No Endo
employee may engage in any transaction in
Endo or another company’s securities while
he or she is aware of inside information.
Illustrative examples of potentially inside
information are information about a
potential business acquisition, internal
information about revenues, earnings or
other aspects of financial performance that
have not yet been publicly disclosed or
that depart from what the market would
expect based upon prior disclosures,
important business developments
(including research and development
results, regulatory approvals or non-
approvals of one of our products), the
acquisition or loss of a major customer or
an important transaction.
Certain employees, known as “restricted
personnel” under our Insider Trading Policy,
are more likely to have inside information
and are prohibited from trading in any
securities during “restricted periods.”
A “restricted period” generally begins
two weeks prior to the end of each fiscal
quarter or year and ends when the market
opens on the third day after earnings are
released for each fiscal quarter or year.
✓ The Endo Way
• Adhere to Endo’s Insider Trading Policy
• Never purchase or sell or direct anyone
else to purchase or sell any type of
security while you are aware of inside
information about Endo or any other
company
• Be familiar with Endo’s “restricted
periods” and whether you are “restricted
personnel,” subject to a restrictive
trading period due to a heightened risk of
you possessing inside information
• Do not directly or indirectly disclose
(“tip”) inside information to anyone,
including family members and
friends, even if you do not intend for
the tipee to use the information to
buy or sell securities
• Contact our Chief Financial Officer
or Chief Legal Officer if you have any
questions
Ethics Hotline: 800-305-1563 | www.endo.ethicspoint.com 35
Intellectual Property and
Confidential Information
Some of our most valued assets are our
intellectual property and confidential
information. Protecting these assets
is critical to our growth. This includes
our patents, trade secrets, trademarks,
copyrights, know-how, data, processes,
experience, customer information and
technical and business knowledge. A
few examples are sales and marketing
databases, marketing
strategies and plans, pricing information,
manufacturing techniques and research
and technical data.
Every Endo employee must protect our
intellectual property and maintain the
secrecy of our confidential information.
Even after employees leave Endo, they
must continue to respect our intellectual
property and not disclose confidential or
proprietary information. Unauthorized
use of the intellectual property or
confidential information of others is also
prohibited.
✓ The Endo Way
• Identify and protect Endo
intellectual property
• Respect valid patents, copyright
materials and the intellectual property
rights of others
• Consult with Endo’s Intellectual Property
legal counsel before soliciting, accepting
or using confidential information
or disclosing Endo’s confidential
information or permitting use of our
intellectual property
• Understand your responsibilities
regarding new inventions and ideas that
you develop as an Endo employee
• Do not develop new products with a third
party without a written agreement that
properly addresses ownership and other
intellectual property rights
• Do not discuss confidential information
in public places
• Do not use confidential information
or intellectual property from other
companies or persons, unless Endo
has the legal right to such use
36 Our Code of Conduct
I overheard Endo employees discussing company business on a train. What
should I do?
If you believe the information is sensitive or confidential, advise the parties they
can be overheard and contact the Legal Department. Every Endo employee has
a responsibility to protect confidential and proprietary information from
inappropriate use or disclosure.
Privacy
Changes in healthcare will increasingly require us
as well as our customers to utilize personal
information. As a global company, our strategy
and daily operations necessitate the collection,
use and, at times, sharing of personal information
about patients as well as our customers,
shareholders and employees.
Many countries in which Endo operates have laws
that govern how we treat personal information.
Before engaging a vendor or other third party to
assist with any handling or sharing of personal
information, particularly personal information of
patients, make sure to consult with Legal so that
the appropriate safeguards can be put in place
to comply with privacy laws in the United States
and abroad. Always follow Endo’s policies and
processes for sharing personal information of
employees, patients or others, and pay
particular attention to policies regarding sharing
that information with Endo’s subsidiaries that
operate outside the United States. Respect for
the privacy of personal information earns the
trust and confidence of patients, customers,
shareholders and employees and we are
committed to adhering to applicable privacy laws
worldwide.
The Endo Way
• Avoid collecting, using or accessing personal
information unless you have a legitimate business
purpose and are authorized to obtain the
information
• Collect the minimum necessary information and
whenever possible do not collect information that
identifies a specific person
• Do not share personal information with
unauthorized individuals or entities
• Respect the privacy preferences of individuals
about how their personal information may be
used
• Third parties and agents to whom we legitimately
disclose personal information should have policies
and appropriate safeguards in place
• Take steps to reasonably ensure that personal
information—particularly sensitive personal
information such as health information—is
appropriately secured in accordance with
Company policies and applicable laws
• In the event of an actual or potential loss or
unauthorized disclosure of personal information,
immediately report the incident to the Ethics
Hotline
• Comply with all Company policies and guidance
documents regarding personal information and
information security, as well as those related to
use of Company resources and Company records
and information management
Ethics Hotline: 800-305-1563 | www.endo.ethicspoint.com 37
One of our vendors who handles personal information on our behalf mentioned that they had a
security problem with one of their data systems that includes personal information. What should I
do?
Report this to the Ethics Hotline immediately. Endo will assess whether there may have been a security breach
involving personal information and determine an appropriate response based on this assessment. Prior to
initiating a relationship with a vendor who handles personal information on our behalf, steps should be taken
to confirm that appropriate policies and safeguards are in place.
Financial Integrity
To fulfill our commitment to our
shareholders, the public and government
agencies, our books and records must
fairly represent in all material respects the
financial condition, operational results and
cash flows of the Company. Endo
employees are responsible for being aware
of and adhering to our system of internal
financial controls and Company policies.
Our internal controls are designed to
provide reasonable assurance regarding
the effectiveness and efficiency of our
operations, the reliability of our financial
reporting, and our compliance with
applicable laws and regulations. You should
always assist in taking corrective actions
in the case of a control failure, reporting
any policies or procedures that are not
being followed and identifying any control
weaknesses.
✓ The Endo Way
• Prepare and maintain accurate and
complete Company records
• Only sign records you believe to be
accurate and complete after appropriate
review
• Financial transactions must be
appropriately authorized, be recorded
in the accounting period in which they
were incurred and be in the appropriate
accounts with supporting documentation
• Be transparent and do not withhold
information from our independent or
internal auditors
• Never falsify records, misrepresent facts
or circumvent our controls
• Always exercise great care when
handling financial transactions and
reporting for the Company to ensure
the accuracy of Company accounts,
and to protect the security of
Company funds
38 Our Code of Conduct
My manager asked me to ship my distributors double the amount of products
typically sold to boost our quarterly sales figures. What should I do?
Do not compromise your integrity. The practice of knowingly selling more products
than your distributors can sell is illegal. Raise this issue with your finance or
compliance leader or your legal contact. You may also contact the Ethics Hotline.
38 Our Code of Conduct
Can I check my
personal e-mail
from work?
Generally, you may check
your personal e-mail or
access
the Internet using
Company systems for
limited personal purposes.
You are still subject to
Company policies. As an
example, it would be
inappropriate to access or
download inappropriate
content from the Internet,
such as sexually explicit,
discriminatory or
otherwise disruptive or
offensive material.
Personal use of Company
systems should be
occasional and not impact
your job performance.
Endo may monitor and
inspect your internet usage
at any time.
Use of Company Systems
and Resources
Each of us is entrusted with the proper
use of Company systems and resources.
Although the incidental and occasional
personal use of our systems subject to
certain restrictions is permitted, these
systems and resources should be used
for legitimate business purposes. Except
where required by local law, the privacy of
information stored on or sent to or from
Company systems is not guaranteed. Endo
may inspect your files or other information
contained on its servers or other property,
including devices, at any time and without
prior notice.
✓ The Endo Way
• Do not use any Endo system or device
to send or access inappropriate,
harassing, discriminatory, sexually
explicit or defamatory material
• Safeguard your system passwords and
do not share them except for a valid
business reason (such as technical
support) after which they should be
changed
• Do not record communications without
proper authorization and only as
otherwise permitted under local law
• Do not leave Endo computers or devices
unattended in places where they could
be accessed or misused by unauthorized
persons
• Treat all computer data as confidential
Company Records and
Information Management
Endo employees must accurately create,
maintain, store and, when appropriate and in
compliance with policy, destroy Company records
- in a manner that protects the integrity of the
information. Effective records management
facilitates sound decision-making, promotes
operational efficiency and is integral to
addressing our legal, financial, regulatory and
contractual obligations.
Company records are viewed broadly and
include records in all mediums such as
paper (including handwritten notes), audio
or video recordings and computer-based
information, including e-mails and electronic
files. You should comply with Company
records management policies and retention
schedules. Requests by third parties (such
as governmental agencies), lawsuits or
other inquiries may necessitate the need
to hold records beyond normal retention
schedules. It is Endo policy to preserve any
records relevant to a “Legal Hold” or any
other “Hold Order” issued.
✓ The Endo Way
• Be knowledgeable of how Company records management policies
apply to your job responsibilities
• Retain records for the time period specified by applicable laws,
Company policies and retention schedules
• If you receive a “Hold Order,” take special care to retain all documents
or other records relevant to the “Hold Order”
• Comply with all Endo policies and guidance documents regarding records
management, including Company policies and procedures regarding
information security.
• Timely complete all training requirements concerning Company records,
information management, data integrity, privacy and information
security.
• Never conceal, alter or destroy records relating to an imminent or
ongoing investigation, lawsuit or inquiry
• Never leave Company documents unattended in public places and report
any accidental loss or destruction of documents
Ethics Hotline: 800-305-1563 | www.endo.ethicspoint.com 39
Corporate Affairs and Investor
and Media Relations
Endo is committed to delivering accurate,
reliable, timely and fact based information
to financial analysts, investors, the media
and members of the public. To facilitate
the appropriate provision of information,
outside inquiries related to Endo or our
business units should be directed to
Corporate Affairs. If an Endo employee
is contacted by a representative of a
government agency, an attorney or a
representative of an attorney seeking an
interview or making a non-routine request
for documents, the Legal Department
should be contacted immediately. Endo
employees should not make statements to
the media about the Company’s business
without appropriate authorization. Any
media inquiries should be immediately sent
to Corporate Affairs.
✓ The Endo Way
• Do not provide any information about
Endo or its businesses to outside
sources, including the media, financial
analysts, governmental officials,
attorneys or their representatives
without appropriate authorization
• If you are asked for information about
current or former employees, refer the
request to Human Resources
• If contacted by a government agency
related to an inquiry, politely inform
the government representative that
as a matter of Company policy you
are required to refrain from providing
information until you have contacted the
Legal Department
40 Our Code of Conduct
I have been asked to speak at a conference about my areas of expertise
at Endo. Can I do this?
Invitations to speak on your area of expertise as a representative of the Company
should not be accepted without prior approval from your manager and the
Corporate Affairs Department. In the event that your presentation may reveal
confidential information or impact our ability to protect our intellectual property,
you should consult with the Legal Department.
Compliance at Endo
Acting with Respect, Trust and Integrity—
Everyone’s Business and the Endo Way.
Ethics Hotline
800-305-1563
Visit
www.endo.ethicspoint.com
to report a concern
or access toll-free
international numbers
Where can I get further
information on Endo’s
Compliance Program?
Further information is available at the
Corporate Compliance and Business
Practices Department’s intranet site
at http://at.endo.com/ourbusiness/
departments/corpcompliance. This
site contains contact information for
your business compliance leaders
and information about Company
compliance policies and procedures
as well as educational and training
efforts.
Compliance at Endo
Our Compliance Program
The Compliance and Business Practices
Department oversees our Company’s
compliance program which is founded on
our Company’s values and its commitment
to ethics and compliance. The Department
maintains an effective company-wide
compliance program by establishing clear
rules of business conduct, educating and
training our employees and conducting
ongoing monitoring to maintain a program
that is operating as intended and to
enhance its effectiveness.
The Department also strives to establish
relationships founded on trust,
collaboration and mutual respect that
are the basis for a proactive and
sustainable approach to ethics and
compliance.
✓ The Endo Way
• Oversight by our Board of Directors
through a compliance sub-committee
that receives at least quarterly
updates on Endo’s compliance
program
• Our Chief Compliance Officer reports
directly to our Chief Executive Officer
and may also report compliance matters
directly to the Board of Directors
• Our Global and U.S. Compliance
Committees, both of which are
comprised of members of the Executive
Leadership Team and other senior
leaders, oversee, assess and enhance
our compliance program and supports
Endo’s strategic approach to compliance
both in the U.S. branded
pharmaceuticals business and
throughout all of Endo’s businesses
worldwide
• Operate in accordance with written
standards, such as this Code of Conduct
and business unit compliance policies
• Promote and support ongoing education
and training of our employees on this
Code, Company policies and applicable
laws
• Oversee the monitoring and auditing of
our compliance with Company policies
and procedures
• Conduct fair, objective and timely
investigations of potential compliance
violations
• Respond appropriately to violations
and adopt corrective and preventative
measures, where appropriate
42 Our Code of Conduct
Acting with
Respect, Trust
and Integrity
The Endo Way
✓ The Endo Way
• Act with honesty, fairness, integrity and personal accountability to protect
our reputation
• Never compromise your integrity for the sake of “making the numbers” or
due to pressure from a supervisor
• Respect fellow staff, government officials, business partners, competitors,
customers and patients
• Know and follow the rules and seek guidance
• Sustain a culture where ethical conduct is expected, recognized
and valued
• Report known or suspected violations of this Code
• Cooperate with investigations—always be forthcoming and tell the truth
• No form of retaliation or intimidation against an employee who makes a
good-faith report of a suspected violation or participates in good faith in
any investigation of a suspected violation will be tolerated
Ethics Hotline: 800-305-1563 | www.endo.ethicspoint.com 43
Endo
www.endo.com
ENG-AUG2017