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Purchasing Controls

In calendar 2020 Lannett added the following statement to all of its purchase orders.

ANTI-BRIBERY/ANTI-CORRUPTION POLICY AND GIFTS AND BUSINESS ENTERTAINMENT POLICY.

“Vendor represents and warrants that Vendor and any of its subsidiaries or affiliates or any of its or their respective directors, officers, managers, employees, independent contractors, representatives or agents will comply with LANNETT’S Anti-Bribery / Anti-Corruption Policy found at https://www.lannett.com/wp-content/uploads/2020/08/Anti-Bribery_Anti-Corruption-Policy.docx.pdf and Gifts and Business Entertainment Policy found at https://www.lannett.com/wp-content/uploads/2020/08/Gifts-and-Business-Entertainment-Policy.docx.pdf. Vendor further represents that it shall and shall cause each of its subsidiaries or affiliates to, maintain systems of internal controls to ensure compliance with the above named policies. Vendor further represents and warrants that it will notify LANNETT within five (5) business days of any known or suspected violations of the representations and warranties made in this Section 25. The parties agree and acknowledge that the audit rights contained in Section 8 herein permit LANNETT to audit Vendor’s compliance with the representations made in this Section.”

We are in the process of informing over 2000 of our suppliers of our code of conduct requirements that are a condition of doing business with Lannett. Below is our communication.