Code of Business Conduct and Ethics

1. Maintain a work environment that encourages open communication regarding legal or ethical problems and concerns.
2. Make a personal commitment that we will operate in accordance with the highest attainable standards of ethical business conduct, and communicate this commitment to all Personnel.
3. Ensure that all Personnel receive appropriate training with respect to the Code.
4. Be familiar with the resources available to assist in the resolution of legal and ethical questions and concerns.

Note that the test is not whether a particular meal, gift or other benefit was actually provided to obtain favorable treatment, but whether it might give the appearance of having been provided for that reason. We apply this test in order to maintain the trust and confidence of our customers and others in our industry. We must refrain from any conduct suggesting that we seek business based on considerations other than the quality of our Personnel, products and services.

1. With respect to non-government personnel, no gifts, meals, entertainment or benefits of any kind in excess of the expense reporting guidelines will be provided without the prior approval of the Chief Financial Officer.
2. With respect to government employees or elected officials, no gifts, meals, entertainment or benefits whatsoever will be provided.

Often it will be clear from the face of relevant documents and/or the circumstances that certain information is proprietary and therefore should not be used. For example, if you receive a competitor’s proposal in the mail from an unknown source, do not read it or use it. Turn it over to the Legal Department. Severe criminal and civil penalties can be imposed if information is used when its release was unauthorized.

The following are some examples of actions prohibited by the antitrust laws:

1. Agreeing with a competitor to divide customers or territories.
2. Agreeing with a competitor that both companies will jointly cease doing business with a customer unless the customer takes certain actions.
3. Engaging in unfair methods of competition, which include making false statements about a competitor’s products and making false or misleading advertising claims.

1. We must comply with generally accepted accounting principles and internal controls, as established by appropriate company officials, at all times. All assets, liabilities, revenues and expenses of Mylan are to be entered in regular Company books, records and other standard financial documents. These books, records and documents must also accurately reflect and properly describe the transactions they record. For example:
   
   
   1. No undisclosed or unrecorded fund, asset, liability or account of the Company will be established for any purpose.
   2. No false or artificial entries will be made in the books, records or accounts of the Company for any reason, and no Personnel will engage in any arrangement that results in prohibited entries.
   3. No payment on behalf of the Company will be approved or made with the intention or understanding that any part is to be used for any purpose other than that described by the supporting documents.

   A variety of federal laws, both civil and criminal, apply to those who make false statements or false claims to the U.S. government. There can be severe civil and criminal penalties both for individuals and Mylan if these laws are violated.

2. Obviously, you must not submit or concur in the submission of any claim, bid, proposal or related documents that contain false or fictitious information. Beyond that, Personnel responsible for pricing products must comply with any applicable government procurement regulations or customer requirements. Pricing decisions may reflect market conditions but must be entirely independent with respect to our competitors.



3. All expense items associated with travel or local business matters, including airfare, hotel expenses, taxi/limousine services, car rental, business meals, and entertainment, must be accurately and fully documented on expense reports (whether or not they are paid directly) with applicable receipts attached. The documentation should include identification of the customer involved, where a customer is involved, and a brief description of the business purpose that required the expense.

1. Unless we have proper regulatory approval to do so, we must never substitute materials, components, procedures or products, change our manufacturing processes or testing methodology or intentionally fail to provide the required quality controls. Proper approval must be obtained before deviating in any way from standard operating procedures. Supervisors must not place pressure on subordinates that might cause them to deviate from these requirements. Personnel should never be pressured into compromising on quality or deviating from our regulatory requirements.
2. We must always properly perform all required and approved testing to meet our regulatory requirements, and the documentation in support of that testing must be accurate and complete. There must be no unauthorized changes in the testing requirements and no false or inaccurate documentation concerning testing or manufacturing. Once again, supervisors must avoid placing pressure on subordinates that might cause them to deviate from our regulatory requirements.

The word "appear" is most important. Even where there is no actual conflict of interest, the appearance of such a conflict is damaging because it can undermine trust among Personnel and cost us the respect of customers, potential customers and others in the industry. This standard applies to Personnel doing business with the Company, or receiving any financial remuneration or benefit from the Company in excess of salary, bonus or other generally recognized benefits.

If situations arise in which Personnel receive any remuneration over and above approved salary, bonuses, stock options, stock awards, deferred compensation or retirement benefit, the remuneration must be disclosed to the Ethics and Compliance Committee of the Board of Directors. If the committee finds that such remuneration is not material and does not appear to be of a nature that it would influence the business decisions of those receiving the remuneration, the committee may grant a waiver.

The following are types of outside activities that can create conflicts:

1. Ownership and/or substantial management control by Personnel or any member of such person’s immediate family of a substantial interest in any concern that does business with Mylan, whether as a supplier, customer or contractor.
2. Performance by Personnel or a member of such person’s family of services for any outside concern or individual that does business with Mylan, i.e., a relative working for a travel agency doing business with Mylan.
3. Outside employment which conflicts with or might be reasonably expected to conflict with the normal duties of Personnel is prohibited. Anytime your outside activities present a conflict or reasonably could create conflict with your employment with Mylan, you must make full written disclosure of those activities and receive prior written approval from the Ethics and Compliance Department, before engaging in such activities or continuing to do so. Further, you must advise the Human Resources Department of other jobs you hold outside the Company.

In this connection, sexual harassment will absolutely not be tolerated. These principles apply to all aspects of the employment relationship, including application and initial employment, promotion and transfer, selection for training opportunities, and the application of service, retirement, seniority and employee benefit plans and policies.

We have an obligation to perform our work in a safe manner so that we do not cause harm to ourselves or to others. Similarly, we must assure that work conducted under our supervision is performed safely.

Any use or possession of illegal drugs and narcotic substances by Personnel on Company property, or while discharging employment responsibilities is strictly prohibited.

Drug abuse threatens the welfare of the abuser and other Personnel. It is detrimental to the work environment and work ethic. Federal laws prohibit the use or possession of illegal drugs and narcotics. Under no circumstances may such drugs or substances be brought onto Company premises. Of course, Personnel must never work when impaired for any reason, including illegal drugs or alcohol.

Each facility has an environmental and waste disposal program that ensures compliance with all government environmental laws, regulations, permits or licenses. Those of us having responsibilities in these areas must familiarize ourselves with these programs and federal, state and local environmental and waste disposal laws and follow them strictly.