CODE OF ETHICS

The Lannett Company is a generic pharmaceutical firm founded in 1942. We employ a staff of dedicated people who work together to produce drug products that sick people can afford to buy that will treat their illness, make them well, reduce suffering and improve the quality of their lives. To that goal we dedicate ourselves;

TO PROMOTE honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships including interdepartmental conflicts that would compromise the integrity of the drugs manufactured at Lannett;

TO PROMOTE full, fair, accurate, timely, and understandable disclosure in the periodic reports and documents that a registrant files with, or submits to, the U.S. Securities and Exchange Commission and in other public communications made by the registrant and required to be filed. This procedure extends to all regulatory communications between Lannett and the FDA, DEA and other governmental agencies;

TO PROMOTE compliance with applicable governmental rules and regulations covering the Good Manufacturing Practices (GMPs), Good Laboratory Practices (GLPs) and all Standard Operating Procedures (SOPs) issues by Lannett for the operation of its plant;

TO PROMOTE the prompt internal reporting to an appropriate person or persons of violations of the code. Those designated as the persons to contact are the President, Chief Executive Officer, Chairman of the Board of Directors, Lannett’s outside counsel (Sam Israel, Esq. at FoxRothschild) and Lannett’s whistle blower hotline. Telephone numbers and or addresses can be obtained from the Human Resources department.

TO PROMOTE accountability, corporate governance and adherence to the Code of Ethics

Admin/Code of Ethics rev. 07/09/07

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