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Corporate Compliance Investigations

Failure to Comply

Failure to comply with this Policy's mandate of acting in accordance with the applicable legal and highest ethical principles may result in disciplinary action by DEY®, up to and including discharge.

Reporting Compliance Violations

Employees should address any questions or concerns regarding the Compliance Program or DEY's business practices to the Office of Compliance or other management personnel. All employees are made aware that reports can be made anonymously. Compliance reports can be made by calling the Compliance Hotline Network . Additionally, concerns may also be directed to any members of the Corporate Compliance Committee or management.

As set forth in DEY's Compliance Program dealing with specific areas of corporate conduct, penalties for an employee's failure to comply with the law are severe. Failure to comply with any of DEY's policies that mandate of acting in accordance with the applicable legal and highest ethical principles may result in disciplinary action by DEY, up to and including discharge. The Office of Compliance is charged with making the determination of whether a reported practice warrants further investigation.

No employee who in good faith reports suspected wrongdoing will be subject to retaliation or discipline for having done so, even if the information incriminates management, supervisors, or other employees, even if the report ultimately is established to be erroneous.