Spirit Pharmaceuticals requires that all suppliers and vendors that work with Spirit produce and supply products in facilities that meet specific criteria that match and reflects Spirit’s own code of conduct, as set forth below:

COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS

Our vendors and the factories in which the product they sell us is manufactured must comply with all applicable laws and regulations, including, but not limited to, animal protection laws.

ETHICAL BUSINESS STANDARDS

Our vendors must not engage in or attempt to engage in bribery, corruption, or similar unethical business practices in dealing with government officials or private individuals or entities.

HEALTH AND SAFETY

Our vendors must provide their workers with safe and healthy conditions, including in any living facilities that may be provided.

CHILD LABOR

Our vendors must not use child labor. The term “child” is defined as anyone younger than 18 years of age. At all times our vendors must respect compulsory education laws. Workers under the age of 18 must not perform hazardous work.

FORCED LABOR

Our vendors must not use voluntary or involuntary prison labor, indentured labor, bonded labor, labor acquired through slavery or human trafficking, or any forms of involuntary or forced labor. Our vendors must not require workers to surrender any identity papers as a condition of employment; such documents may only be temporarily held to verify a worker’s employment eligibility. Our vendors must reimburse their workers for any recruitment or hire fees that are paid.

WAGES AND BENEFITS

Our vendors must abide by all applicable laws relating to wages and benefits, and must pay the legally prescribed minimum wage or higher. Workers must be provided with a written notice that clearly describes their employment and wage terms prior to acceptance of employment. Our vendors must not make any deductions from wages as a disciplinary measure.

OPERATING /WORKING HOURS

Our vendors must not require their employees, on a regularly scheduled basis, to work in excess of 50 hours per week (or fewer hours if prescribed by applicable laws and regulations). All overtime must be voluntary and must be fully compensated in accordance with the requirements of local law, and except in extraordinary circumstances, employees must be entitled to at least one day of rest in every seven-day period.

HARASSMENT OR ABUSE

Our vendors must respect the rights and dignity of their employees. We will not tolerate human rights abuses, including physical, sexual, psychological, or verbal harassment or abuse of workers.

DISCRIMINATION

Workers must be employed, retained, and compensated based on their ability to perform their jobs, and must not be discriminated against on the basis of gender, race, color, national origin, religious, ethnic or cultural beliefs, age, sexual orientation, or any other protected class.

FREEDOM OF ASSOCIATION

Our vendors must respect the rights of their workers to choose (or choose not) to freely associate and to bargain collectively where such rights are recognized by law. We prohibit harassment, retaliation, and acts of violence against trade union members and representatives.

ENVIRONMENT

Our vendors must be in compliance with all applicable environmental laws and regulations. Our vendors are strongly encouraged to protect the environment by operating in a sustainable manner, where possible; conserving and protecting resources, such as water and energy; and taking into consideration environmental issues that may impact local communities.

MONITORING AND COMPLIANCE

Spirit Pharmaceuticals LLC or its designated third party auditor or agent shall have the right to monitor and assess compliance with these principles. Our vendors must be transparent and honest in all communications with Spirit Pharmaceuticals, our auditors and agents. A violation of this Code of Conduct may result in required corrective action, cancellation of the purchase order(s), and/or termination of the business relationship.