Compliance and Ethics Program

Lupin has a Corporate Compliance and Ethics Office (CCEO), which focuses on the development and enhancement of our Compliance Program to ensure it is designed to meet external requirements and guided by our values of integrity, excellence and respect for people.

Lupin has a global Chief Compliance Officer (CCO) who has a direct reporting line to the Chief Executive Officer (CEO) and access to the Board of Directors. The CCEO provides dedicated support to Lupin employees and has access to and makes reports regarding compliance matters to the CEO and other senior-level leaders.

Lupin fosters a culture of integrity, promoting open-door dialogue between management and employees in an environment free from retaliation. Employees are obligated and encouraged to report Referable Compliance Issues (RCIs), which are suspected, potential, or actual violations of laws, regulations, or Lupin policies.

Lupin provides multiple channels, such as by phone or an online platform, for anyone – employees, Business Partners (e.g. suppliers), and others – to raise concerns or report violations.

The Company’s Speak Up Line can be reached 24/7 in multiple languages, and local numbers for each country are provided on the Speak Up website. Callers can raise concerns confidentially or anonymously through these channels.

To report a concern, you can access Lupin’s Speak Up website here ( EthicsPoint - Lupin) Or the Compliance & Ethics Office can be reached directly at ComplianceandEthicsOffice@lupin.com

We have documented policies and processes in place to inform employees of expectations and maintain our high standards. Our clear, principles-based and comprehensive policies can easily be accessed internally via our Compliance intranet.

Lupin's ethical standards are upheld through our policies and procedures, which also aim to mitigate risks identified during risk assessment.

The Code is based on Lupin’s values and principles, resonating across horizons. It emphasizes our commitment to integrity in every relationship and with every transaction. Our Code describes our commitment to the people we serve – employees, shareholders, customers, business partners, patients, healthcare providers and the public.

Lupin's Code of Business Conduct and Ethics  (the “Code”), along with our policies, standard operating procedures (SOPs), and other documentation, outline standards and guidelines for employee conduct.

These materials incorporate relevant laws, regulations, and industry best practices, setting clear expectations for ethical and compliant behavior for all employees, whether working directly for Lupin or on its behalf. Our policies and procedures undergo regular review and updates to ensure alignment with current laws and regulations.

Lupin is dedicated to providing effective training and education to empower our employees with a deep understanding of Lupin's values, Code of Business Conduct and Ethics, company policies, and individual responsibilities. Targeted trainings, especially for roles in high-risk areas such as pharmaceutical sales and marketing, are mandatory. The CCEO regularly revises and enhances our training materials to keep employees informed about the latest policies and legal requirements.

Our Compliance and Ethics Office training program helps employees and board members to operate with integrity and understand Lupin's standards. We provide online, virtual, and live training sessions, incorporating scenario-based materials to enhance engagement and comprehension. Our online Compliance training program and the Disclosure functionality allows our employees to fulfill certain policy training requirements and reporting obligations.

Lupin’s Corporate Compliance & Ethics Program includes ongoing efforts to assess, evaluate, monitor and audit compliance with the law, the Code of Business Conduct & Ethics, policies, and procedures.

The nature, extent, and frequency of these activities depend on a variety of factors, including new regulatory requirements, changes in business practices, and other considerations.

Lupin prioritizes integrity and takes employee concerns seriously, thoroughly assessing all reports of alleged misconduct. Investigations are conducted as needed, and the cooperation and transparency of all involved colleagues are essential for their effectiveness. Employees are required to fully cooperate with any inquiries from the CCEO.

Every reported matter undergoes assessment and confidentiality, and anonymity is protected to the greatest extent possible. Corrective actions are determined based on individual circumstances.

We conduct risk assessments of the organization to identify and evaluate possible significant and emerging compliance risks.

These efforts aid in resource allocation and the implementation of effective mitigation measures. When the business proactively partners with us, we are able to evaluate potential new risks and behaviors to ensure appropriate safeguards are in place.

Lupin strives to engage third parties committed to ethical conduct and compliance with laws and regulations. Our risk-based approach evaluates third parties across various factors to mitigate potential risks, ensuring that our business relationships are built on integrity.

The due diligence process is on-going and identifies a risk rating for existing and new Third Parties based on identified risk factors.