The Barr Group is committed to being the leading global specialty pharmaceutical company distinguished by its ability to:

We will accomplish these tasks while exhibiting the highest levels of integrity and corporate citizenship.

back to top


Our vision for success is clearly articulated. To accomplish it, however, we must all adhere to the highest levels of integrity in all that we do, and must ensure that our commitment to our co-workers, our customers and the communities in which we live and work is unwavering.

Our commitment to the highest ethical values and our individual and collective compliance with the policies and laws that regulate our activities is critical to our success, our reputation for leadership in our industry, and enhances Barr as a great place to work.

Our Code of Conduct provides guidelines as to how we conduct our activities and interact with our customers, suppliers, business partners, government officials and fellow employees. Since no code of conduct can anticipate and cover every business scenario or define all elements of acceptable behavior, good business judgment and common sense is your best guide when our Code of Conduct does not specifically deal with an issue or circumstance. When you are not sure of activities or situations that arise in which the Code of Conduct does not provide specific guidelines you should consult with your supervisor, or local or Corporate Human Resources representative.

For further guidance or, to report a potential or actual violation of the standards detailed in the Code of Conduct, we have established a dedicated telephone helpline and a secure internet connection. To access either the helpline number or the web reporting tool, you can visit the Barr Group Intranet or access the website These anonymous reporting resources are available to respond to your inquiry 24 hours a day, seven days a week, in almost any language. All information you provide will be kept confidential, except where disclosure is required by laws, rules or regulations or legal process. It is the Barr Group’s policy to strictly prohibit any form of retaliation against those who in good faith report potential violations of company policy or applicable law.

We are committed to the highest standards of behavior at Barr. Each of us plays a critical role in meeting these high standards and creating an environment of compliance that will protect Barr’s reputation and ensure a solid foundation for long-term success.

Bruce Downey
Chairman, CEO and President
December 20, 2007

back to top

Barr Pharmaceuticals, Inc. Code of Business Conduct

         I.            Overview

The Board of Directors of Barr Pharmaceuticals, Inc. (the “Board”) has adopted the following Code of Business Conduct (the "Code of Conduct"). This Code of Conduct applies to Barr Pharmaceuticals, Inc., all of its directly or indirectly controlled subsidiaries worldwide and their respective officers, directors and employees. Barr Pharmaceuticals, Inc. and its directly or indirectly controlled subsidiaries worldwide are referred to collectively herein as “Barr”. Additional policies, regulations, procedures and practices that supplement, support and/or clarify the policies in this Code of Conduct are in place at Barr.

No code or policy can anticipate every situation or provide definitive answers to all questions that may arise. Accordingly, this Code of Conduct is intended to focus each individual director, officer and employee on areas of ethical risk, provide guidance to directors, officers and employees to help them recognize and deal with ethical issues, establish mechanisms to report inappropriate conduct, and help foster the Barr values and operating principles. When in doubt about the best course of action, employees are encouraged to bring questions about particular circumstances to the attention of their supervisor, their local or Corporate Human Resources representative and/or by using a dedicated telephone helpline or secure internet connection. To access either the helpline number (the “Compliance Helpline”) or the web reporting tool, you can visit the Barr Group Intranet or access the website (the “Compliance Weblink”), as listed in Section XVIII of this Code of Conduct. Members of the Board should contact the Barr Pharmaceuticals Company's Chief Executive Officer or General Counsel.

back to top

        II.            Compliance with the Code of Conduct, Governmental Laws, Rules and Regulations

It is the responsibility of Barr management to ensure that this Code of Conduct and the standards set forth herein are communicated throughout Barr, that procedures for promoting and monitoring compliance are established and that appropriate measures are taken in connection with any breach of this Code of Conduct. While management is expected to take a leadership role in promoting this Code of Conduct, the cooperation and active engagement of each employee is critical to its successful implementation.

All employees are expected to familiarize themselves with this Code of Conduct and, as applicable, to certify on a regular basis that they have done so and that they are in compliance with the Code of Conduct (each such certification a “Certification”), and Barr shall ensure that the Code of Conduct is readily available to all of its employees. If an employee has questions concerning the interpretation or application of standards set out in this Code of Conduct, it is the employee's responsibility to consult, as necessary:

                                o            his/her supervisor;

                                o            a local or Corporate representative from the Human Resources Department; or

                                o            the Compliance Helpline and/or Compliance Weblink available at

Barr policy requires that we comply with all applicable laws, rules and regulations, and Barr expects its directors, officers and employees to carry out their responsibilities on behalf of Barr in accordance with such laws, rules and regulations and to refrain from illegal or inappropriate conduct. No individual is expected to know the details of all applicable laws, rules and regulations. Nevertheless, individuals who have questions about whether particular circumstances may involve illegal or inappropriate conduct should seek advice from their local or Corporate Legal Department representative.

Barr encourages any individual who believes in good faith that any violation of the principles set out by this Code of Conduct has occurred to report such a violation to either his/her supervisor, a local or Corporate Human Resources representative, or the Compliance Helpline or Compliance Weblink listed on the last page of this Code of Conduct. Information received in connection with the implementation or potential or actual violation of the Code of Conduct will be treated confidentially, except where disclosure is required by laws, rules or regulations or legal process. Barr policy strictly prohibits any form of retaliation for reporting misconduct to protect those who report misconduct in good faith.

back to top

      III.            Confidentiality

Directors, officers and employees must maintain the confidentiality of non-public information and records entrusted to them by Barr, and any other confidential information that comes to them, from whatever source, in the course of performing their responsibilities as a director, officer or employee, except when disclosure is authorized by the appropriate local or Corporate Legal Department representative (in communication with General Counsel) or required by laws, rules, regulations or legal process.

In the event that an employee is uncertain whether certain information is confidential, he/she should presume that it is. Any information generated within Barr and which represents a business secret or is confidential in any way, whatsoever, must not be disclosed outside Barr without proper authorization and subject to applicable laws, and may not be used by a Barr employee or disclosed, directly or indirectly, to a third party, whether during or after employment with Barr. Barr employees are also required to respect the confidentiality of information obtained from third parties.

back to top

      IV.            Corporate Opportunities; Conflicts of Interest

Directors, officers and employees are prohibited from taking for themselves personally opportunities in which they could reasonably anticipate that Barr might have an interest. A “corporate opportunity” is a business opportunity that Barr might reasonably be interested in pursuing (i) which has a direct or close relationship to a business or line of business in which a Barr company is currently engaged or (ii) in which Barr has publicly announced it intends to engage (or the director or employee at issue is aware Barr intends to engage). Limited exceptions to this policy may be authorized only after full disclosure of the facts is made in accordance with the procedures outlined under "Compliance Standards, Reporting and Disciplinary Action" below, and a determination by the General Counsel or his designee that such exception does not violate the Code of Conduct or local laws or policies.

It is Barr’s policy that all directors, officers and employees are to act in the best interests of Barr, to refrain from competing with Barr and to avoid business and personal situations that may give rise to a conflict of interest. A "conflict of interest" occurs when an individual's private interest interferes or gives the appearance of interfering with Barr’s interests. No employee, by virtue of his/her position, should seek to personally profit in any manner adverse to Barr's interest, either directly or indirectly, whether for himself/ herself or for the benefit of any other person. Employees should avoid putting themselves in situations where their private, financial or business interest may be in conflict with those of Barr or their responsibilities to Barr.

A conflict of interest can arise in numerous areas including, but not limited to, the situations listed below. Barr directors, officers and employees do not, for example:

                                o            take actions or have interests that may make it difficult to perform their work on behalf of Barr objectively and effectively.

                                o            have a direct or indirect interest (other than ownership of a non-material interest in a publicly traded company) in a transaction where Barr is or may become a party, property that Barr may acquire, or an entity with which Barr does or may do business, except where full disclosure of the facts is made to Barr in accordance with the procedures outlined under "Compliance Standards, Reporting and Disciplinary Action" below.

                                o            have a family member who receives improper personal benefits as a result of his or her position as a director, officer or employee of a Barr company.

                                o            have a personal or family interest in any specific transaction with Barr

                                o            have an interest (other than ownership of a non-material interest in a publicly traded company) in a supplier, customer, competitor or any other partner of Barr, whether by holding directly or indirectly a “stake" in such a company, having an influence in the decision making process of such a company, or, holding a position of director or senior manager of such a company, whether personally or through a family member.

                                o            directly or indirectly influence, in a manner that is detrimental to Barr’s interests, Barr's dealings with any supplier with whom they have a personal, family or financial relationship;

                                o            work for or represent a customer or supplier in its dealings with any Barr company;

                                o            accept preferential stock offerings that are generally unavailable to the investing public (e.g., "friends and family" stock programs) from companies with whom Barr does business; or

                                o            Use Barr's name, information, property, time or other resources to perform outside activities, such as working a second job or performing volunteer work or community service not specifically sponsored or approved by Barr. These activities must always be kept separate from an individual’s employment with Barr.

Common Questions:

My sister owns a business and is trying to become a supplier for a Barr company. May I help direct her to the appropriate party within Barr?

Subject to applicable law, you may make the introduction. However, the decision-maker within Barr should be made aware of the relationship and must comply with applicable sourcing strategy and procedures. In addition, you may not participate in the decision-making process or otherwise unduly influence the process. In addition, you must promptly disclose the relationship to your supervisor and in your Certification.

My spouse and I own a small graphic design business. The work I do for that business is completely unrelated to my job with Barr. I am sure that my small business could provide Barr with a superior product at reduced cost. May I be both an employee and a supplier to Barr?

Your primary obligation is to Barr and providing services as a vendor could be a conflict of interest. Subject to applicable law, you could bid on Barr jobs provided that: 1) you do not use your Barr employment to influence the bidding process; 2) you do not participate in the performance or evaluation of the work; and 3) the relationship is reported to your supervisor and disclosed in your certification.

Are there any restrictions on my having a second job outside of Barr?

Yes. You are free to use your own time as you see fit. However, your employment outside of Barr must not create, or appear to create, a conflict of interest with your responsibilities at Barr. For example, you must not accept a job that could discredit Barr or interfere with the independence and objectivity of your judgment. Your second employment must be kept totally separate from your Barr employment. In no event may you use Barr's name, information, time, property or other resources to perform your second job subject to the limited exceptions provided in Section VIII of this Code of Conduct (“Protection and Proper Use of Assets”). Any employee who works outside of Barr continues to be bound by all confidentiality agreements he/she has with the company. Employees may not work for, consult with or otherwise assist a business that competes with Barr.

A Barr supplier has offered me the opportunity to buy stock in the supplier’s initial public offering (“IPO”). May I purchase the stock?

No. In this case, you would be obtaining a personal benefit from the supplier because of your position at Barr and Barr's relationship with the supplier. Therefore, you may not participate in the supplier's stock offering.

Employees should contact their supervisor for help in sorting through situations that may give rise to potential conflicts of interest. Members of the Board should direct questions to Barr Pharmaceuticals, Inc.’s Chief Executive Officer and/or General Counsel.

A vendor has invited me to attend a three-day conference at a major resort with one of the leisure activities being an invitation to the Daytona 500. May I accept the invitation?

You may accept the invitation provided that your participation at the conference has a business purpose, is important to Barr’s business, the conference is primarily business-related and you have obtained prior management approval consistent with Barr’s Approval matrix and Travel Policy. It is also important that such approval is viewed in conjunction with any conflict of interest or appearance of a conflict of interest, or otherwise does not influence your judgment or business decisions.

back to top

        V.            Compliance with Securities Laws

Barr Pharmaceuticals, Inc. is often required by the securities laws of the United States and other jurisdictions to disclose to the public important information regarding Barr. All such disclosure, as well as all public communications, should be full, fair, accurate, timely and understandable. A director, officer or employee who knows important information about Barr that has not been disclosed to the public (referred to as “material non-public information”) must keep such information confidential. It is unlawful to purchase or sell Barr Pharmaceuticals, Inc. securities on the basis of such material non-public information. Directors, officers and employees may not do so and may not provide such information to others for that or any other purpose. Directors, officers and employees also may not buy or sell securities of any other company using material non-public information obtained in the performance of their duties; nor may they provide such information so obtained to others. Violation of this policy may lead to civil and criminal penalties.

It is not possible to define all categories of information, the use of which could result in improper securities trading. However, non-public information should be regarded as material if there is a reasonable likelihood that it would be considered important to an investor in making an investment decision regarding the purchase or sale of securities, as well as if it could impact the share price if publicly disclosed. Information such as financial results, projections of future earnings or loses, news of the acquisition or disposal of material assets or a business entity, financial liquidity problems, gain or loss of a substantial customer or supplier, significant new product announcements, new equity or debt offerings, etc. should always be considered material.

Employees are responsible for becoming familiar with Barr’s Insider Trading Policy and should consult it before engaging in any transaction involving the securities of Barr Pharmaceuticals, Inc.

back to top

      VI.            Fair Dealing

Barr companies aim to succeed through fair and honest competition. Barr seeks superior performance, but never through unethical or illegal business practices. Directors, officers and employees should endeavor to deal fairly with customers, suppliers, competitors and employees. No one should take unfair advantage of another individual through manipulation, concealment, abuse of privileged information, or misrepresentation of material facts. It is Barr’s policy to respect the trade secrets and proprietary information of others. Although information obtained from the public domain is a legitimate source of competitive information, a trade secret obtained through improper means is not. If a competitor's trade secrets or proprietary information are offered to an employee in a suspicious manner, or if an employee has any question about the legitimacy of the use or acquisition of competitive information, contact your local or Corporate Legal Department representative immediately. Sales of Barr products and services, and purchases of products and services of suppliers, shall be made solely on the basis of quality, price and service, and never on the basis of giving or receiving payments, gifts, entertainment or favors. No Barr funds, assets or information shall be used for any unlawful purpose. No employee shall purchase privileges or special benefits through payment of bribes, illegal political contributions, or other illicit payments or otherwise give anything of value to a government official in order to influence inappropriately any act or decision on the part of the official. No undisclosed or unrecorded fund or asset shall be established for any purpose. No false or artificial entries shall be made in Barr books and records for any reason, and no employee shall engage in any arrangement that results in such prohibited act, even if directed to do so by a supervisor. No payment shall be approved or made with the agreement or understanding that any part of such payment is to be used for any purpose other than that described by documents supporting the payment.

Common Question:

Can a Barr Employee contact a competitor to obtain competitive information?

It depends on the situation. While Barr employees are not restricted from obtaining information on a competitor that is already publicly available, Barr employees should never contact a competitor to obtain privileged and confidential competitive information, including pricing information. Some forms of contact with competitors are permitted, however. A Barr employee may, for example, visit a competitor’s booth at a trade show and collect any publicly distributed literature. However, in speaking to the competitor's personnel, Barr employees should not misrepresent their identity or affiliation, and must avoid conversations on the sensitive competition-related subjects listed below under “Antitrust and Competition Laws.” Similarly, in interactions with competitors, Barr employees must never use deceptive practices - posing as a potential customer, for example - to obtain competitive information on behalf of Barr.

back to top

     VII.            Antitrust and Competition Laws

It is Barr’s policy to comply with the antitrust and competition laws of each country in which our companies do business. No employee of Barr shall engage in anti-competitive conduct in violation of any such antitrust or competition law. Certain kinds of agreements (both formal and informal) are absolutely prohibited by these laws. Likewise, Barr policy prohibits Barr employees, contractors, consultants, agents, or anyone working on behalf of Barr to enter into any of these types of agreements. Examples of agreements that violate Barr policy include:

                                o            Agreements or understandings with competitors on price;

                                o            Agreements or understandings with competitors to "divide up" customers, products, services or territories;

                                o            "Bid-rigging" (e.g., reaching a prior agreement with competitors to govern conduct in the bidding process) or making agreements or reaching understandings with competitors not to bid in public or private procurements; and

                                o            Agreements or understandings with competitors to disadvantage other competitors.

Parties entering into these types of agreements can be prosecuted under criminal law, resulting in significant fines for corporations and fines and jail time for the employees involved. An unlawful agreement on "price" can cover a broad range of agreements among competitors that directly or indirectly affect the price of goods or services. This includes, for example, agreements on price ranges, minimum prices, list prices, advertised prices, pricing formulas, discounts, rebates, profit margins, credit and warranty terms or other terms of sale. An "agreement" or "understanding" need not be in writing for it to be unlawful. It can be oral or inferred from the conduct of the parties, as in the following examples:

                                o            An informal observation to a competitor about a company's likely future prices;

                                o            Comments to a competitor about the desirability of an entire industry following a price increase; or

                                o            Comments to a competitor about the desirability of ceasing discounts to certain customers.

These kinds of situations have each been used (along with other circumstantial evidence) to charge companies and individuals with criminal price-fixing. It is for this reason that you should avoid any conduct or activity, formal or informal, from which even an appearance of improper conduct could be drawn. The obligation to scrupulously avoid even an appearance of impropriety applies in business settings, as well as to communications with competitors in casual social settings (golf games, civic events, etc.). In addition, a supplier in one market may be a competitor in another. Conversations that are wholly appropriate in the context of a supplier relationship may be inappropriate when discussions shift to issues relating to areas of competition. There are other activities that, under certain circumstances, may also violate the various antitrust laws and should be reviewed by your local or Corporate Legal Department representative. Examples include:

                                o            Agreements with suppliers or customers not to do business with others;

                                o            Certain exclusive dealing arrangements;

                                o            Significant differences in prices offered to customers or distributors who compete with each other;

                                o            Charging prices that are below cost in order to drive a competitor out of a market;

                                o            Dictating maximum resale prices; or

                                o            Selling products or services only on the condition that the buyer also purchase a second product or service.

Because this area of the law is complex and the penalties for violation are severe, contact your local or Corporate Legal Department representative whenever you have questions about the antitrust laws of the countries in which Barr conducts business.

Common Question:

What subjects should never be discussed with competitors?

Generally, company policy and legal requirements prohibit discussions with competitors regarding, among other things: prices, profit margins, costs, bids, terms or conditions of sale, sales territories, customer lists, production levels or capacities, inventories, proposed new products or services, marketing plans, division of the market and distribution arrangements.

back to top

   VIII.            Protection and Proper Use of Assets

Company assets, such as information, supplies, equipment, materials, intellectual property, software, hardware and facilities, among other Barr properties and assets, are valuable resources owned or licensed by, or otherwise belonging to, Barr and are to be used solely for corporate purposes. Safeguarding this property from loss, damage or theft is the responsibility of all employees. No person shall take Barr property or assets for personal use or gain, nor shall Barr property or assets be given away, sold or traded without proper authorization. Incidental and immaterial personal use of assets such as computers and other equipment, telephones and supplies and other personal usage in accordance with approved policies/procedures are permitted exceptions to this policy.

back to top

       IX.            Government Officials and Employees

As a general rule, no payment, offer or promise to pay money or anything of value may be made or given to any employee or official of any governmental agency.

For purposes of this policy, a person is considered a government official or a government employee if he or she receives any part of his/her salary from the government. Particular care should be given to interactions with government employees who have roles in licensing, approval, pricing, reimbursement, bulk purchases and formulary listings.

The U.S. government and many governments around the world have very strict rules regulating the provision of gifts, entertainment, meals, favors or anything of value to their employees. These rules also apply to government contractors and subcontractors. Barr is committed to complying with all such applicable rules. For more specific guidance, see Section X of this Code of Conduct (“Foreign Corrupt Practices Act”) and Barr’s existing policies on gifts and entertainment, or consult your local or Corporate Legal Department representative

Common Question:

May I invite a U.S. Government employee to participate in a working lunch paid for by Barr?

Yes. However, U.S. government regulations require that the government employee reimburse Barr for the cost of the meal. There are special rules and regulations that Barr employees and contractors must follow if they work on any U.S. government contract or subcontract. Contact your local or Corporate Legal Department representative for further guidance.

back to top

        X.            Foreign Corrupt Practices Act

The Foreign Corrupt Practices Act (“FCPA”) anti-bribery provisions make it unlawful to make any payment to a government employee for the purpose of obtaining or retaining business, for or with, or directing business to, any person. Neither Barr nor any its employees, agents or other representatives should attempt directly or indirectly to influence business by illegal payments, bribes, kickbacks, or other unethical means. Barr policy prohibits the giving or offering of anything of value to government officials, political parties or candidates for political office in order to obtain, retain or direct business to the individual and/or company, or to secure any improper advantage in doing business. Corrupt payments made through agents, representatives, consultants or other third parties also are prohibited.

In many countries where Barr operates, the healthcare professionals with whom the company interacts are government employees. All interactions with healthcare professionals, including sponsorships to medical or scientific congresses or symposia, and any other contractual relationship shall comply with this policy.

The accounting provisions of the FCPA require corporations to keep books and records that accurately and fairly reflect the transactions of the corporation and to devise and maintain an adequate system of internal accounting controls. This means that payments may not be characterized wrongly in an invoice or other document. Barr and its employees, agents and other representatives shall keep books and records that accurately reflect the transactions and dispositions of Barr's assets, and create and maintain a system of internal accounting controls to ensure accurate book and record keeping.

Because Barr has operations in many countries, employees shall be familiar with laws that govern payments to government employees and follow those laws, including the Anti-Bribery and Anti-Corruption Policies that have been implemented by each of Barr’s non-U.S. companies in connection with Barr’s global FCPA compliance program.. Local laws criminalize corrupt payments made, directly or indirectly, to government employees that are intended to secure an improper business advantage for a company. Many of these laws have extraterritorial reach, meaning that a crime can be charged under a country’s laws even if the crime did not happen in that country.

In order to avoid violations of the law, and to avoid the serious consequences attendant to it, including fines and imprisonment of up to five years, all employees, agents and representatives of Barr shall comply with this policy. Failure to follow this policy may subject an employee to severe disciplinary actions up to and including termination. If you have any questions concerning the applicable law of a foreign country, or if a local law conflicts with U.S. law or Barr policies, you should contact your local or Corporate Legal Department representative, or the Vice President of Internal Audit.

back to top

       XI.            Public Reporting and Disclosure

Barr employees are responsible for the timely, accurate and complete reporting of financial and other information within their respective areas of responsibility. Reports and documents that Barr Pharmaceuticals files with or submits to the Securities and Exchange Commission, and other public communications, should contain full, fair, accurate, timely and understandable disclosure. Dishonest reporting of information inside or outside of Barr, including false or artificial entries in books and records, is strictly prohibited. This includes not only inaccurate reporting but also organizing information in a way that is intended to mislead or misinform. Barr's policy is to give government investigators the full measure of assistance to which they are entitled, consistent with the safeguards which the law has established. If any government investigator or agency seeks information or access to Barr’s records or facilities, or if any litigation is threatened or commenced which involves any entity in Barr, contact your local or Corporate Legal Department representative immediately.

back to top

     XII.            Political Contributions

Barr encourages employees to be involved personally in their communities and political affairs. However, no employee shall directly or indirectly use or contribute funds or assets of Barr for or to any political party, candidate or campaign unless such a use or contribution is an accepted practice and lawful in the country involved and is approved by the Legal Department (in communication with General Counsel) and Investor Relations Department. For more information, please see the Barr Political Contributions Policy at under the “Investors” heading.

back to top

    XIII.            Diversity and Equal Opportunity

Barr promotes diversity at all levels of its organization and does not tolerate discrimination based on factors such as an individual’s age, color, handicap, religion, sex, sexual orientation, or other categories established by applicable country, state or local regulations. In addition, any type of workplace harassment, including but not limited to sexual harassment, harassment based on gender, sexual orientation, marital status, race, national or social origin, religious or political belief, culture, age, physical ability and any other harassment unacceptable for any social and business community, is contrary to Barr's core values and will not be tolerated.

Barr is also committed to following applicable labor and employment laws wherever it operates. Behavior that is contrary to the above principles may result in appropriate corrective action and/or disciplinary action up to and including termination of employment, subject to applicable law. Any employee with information regarding violation of the above policies or principles should report the incident and circumstances to his/her local or Corporate Human Resource Department representative, supervisor, and/or to the Compliance Helpline or Compliance Weblink for prompt, impartial and confidential investigation.

back to top

    XIV.            Prohibition Against Retaliation

Barr prohibits retaliation against an individual for reporting an activity that the employee, in good faith, believes to be a violation of any law, policy, regulation or provision of this Code. Retaliation or reprisals against employees are considered a violation of this Code. Any employee who believes he is the subject of any form of retaliation should report the matter to a supervisor, your local or Corporate Human Resources representative or the Compliance Helpline or Compliance Weblink. Other laws make it a crime to retaliate against a person (including with respect to their employment) for providing truthful information to a law enforcement agency or officer relating to the possible commission of any crime.

back to top

     XV.            Privacy

Many Countries have implemented, or are planning to implement, privacy laws that set requirements for the appropriate handling of personal data (any information that can be used to identify, contact or locate an individual).

Barr is committed to protecting the reasonable privacy expectations of those with whom we do business, including customers, consumers and employees. We believe individuals have the right to decide when their personal data is collected, used or disclosed. We also believe that responsible stewardship of personal data is a critical component in maintaining trust in the Barr brand and ensuring that individuals feel confident that Barr respects their right to privacy.

Therefore, all personal information in any Barr company’s possession should be protected following these principles:

                                o            Personal data is collected, processed, stored and transferred with adequate precautions to ensure confidentiality and is accessible only to individuals with legitimate reasons to know or have access to it.

                                o            When appropriate and or required, employees and other individuals will be asked for their consent to the collection, processing, transfer and storage of their personal data.

                                o            Employees will have the opportunity to review their own personal data held by Barr and to correct any errors found.

When questions arise consult your local or Corporate Human Resource Department representative, your supervisor, and/or the Compliance Helpline or Compliance Weblink.

Common Question:

I am a manager with global responsibilities with employees reporting to me in 20 different countries. Would it be appropriate for me to ask for copies of their personnel files to be forwarded to me?

Privacy laws may be vastly different in the countries that we operate and the sharing of such information may not be appropriate. Consult your local or Corporate Human Resources representative or contact the Compliance Helpline or Compliance Weblink with any questions you may have.

back to top

    XVI.            Abuse of Drugs and Alcohol

While Barr respects individual privacy, we also recognize that substance abuse poses serious health and safety hazards in the workplace. Barr is dedicated to achieving a substance-abuse-free environment for the well-being and health of our employees and for the enhancement of our competitive position.

Barr’s policy is designed to eliminate substance abuse. In addition to pre-employment drug testing, employees may be tested on a random basis or when they display unusual behavior or when there is reasonable concern of drug or alcohol abuse to the extent permitted under governing laws.

Common Question:

A fellow worker at our manufacturing plant appears to be coming to work impaired and I am concerned for my safety as well as my fellow workers. I am afraid to confront him. What should I do?

If your co-worker is coming to work and has a substance problem, that employee could be jeopardizing the safety of you or your colleagues as well as affecting the quality of the team’s job performance. If you have reason to believe that the individual is under the influence of drugs or alcohol, please immediately inform your supervisor or your local or Corporate Human Resources representative.

back to top

  XVII.            Use of Barr-provided Computer Assets and Internet and E-mail access

Internet access is provided to Barr's employees for business use. Personal use of these resources must be governed by good judgment and restraint. Barr limits personal use of company resources if such use interferes with the productivity of individual employees or the overall availability of network and computing resources. If you are unsure whether your Internet usage is appropriate, you should discuss this matter with your supervisor. Employees should consider the adverse impact on the Barr network that results from transferring large files during peak use periods.

Use of these resources, whether in the office or at home, is not private. Barr companies can and will monitor individual use of network services, including visits to specific Web sites, and e-mail under established laws, regulations and guidelines. Monitoring of individual usage will extend to individuals using their personal computers to access the Barr network remotely.

Barr's assets and resources, including its computing, telephony, facsimile and networking resources, should never be used to access or disseminate:

                                o            Sexually explicit content;

                                o            Slanderous or libelous content;

                                o            Threatening or harassing messages or chain letters;

                                o            Any information in violation of any laws or Barr policies; or

                                o            Other content that could reasonably be construed as inappropriate.

Employees who violate this policy will be subject to discipline, up to and including dismissal. Questions regarding whether a particular use is permissible, should be addressed to your supervisor.

Common Question:

May I download software from the Internet that would be helpful for my work at Barr?

No. Downloading software from the Internet exposes Barr to the risk of viruses and other malicious code that could affect the integrity and availability of Barr's systems and networks. All software on Barr computers must be appropriately authorized, purchased and licensed.

back to top

 XVIII.            Compliance Standards, Reporting and Disciplinary Action

Barr is committed to operating according to the high standards of business conduct set forth in this Code of Business Conduct. Each director, officer and employee is expected to report what he or she believes in good faith are actual or potential violations of applicable laws or non-compliance with this Code of Conduct by any Barr director, officer or employee. Barr's Human Resources Department is generally responsible for the administration of this Code of Conduct with respect to officers and employees. The Audit Committee of the Board of Directors (or its designee) is generally responsible for enforcement of the Code of Conduct relating to members of the Barr companies Board. The Audit Committee may designate another Board committee or the full Board, as it deems appropriate, to handle the enforcement of a particular Code of Conduct provision as it applies to members of the Board.

Employees should report actual or potential violations of this Code of Conduct involving any Barr officer or employee to their supervisor, their local or Corporate Human Resources representative or via Barr’s Compliance Weblink at, or the toll-free corporate Compliance Helpline (or local country toll-free helpline) as listed on the Compliance Weblink. The Compliance Helpline and Compliance Weblink are available to respond to calls and inquiries 24 hours a day, seven days a week, in most languages. All information provided via the Compliance Helpline or Compliance Weblink will be kept as confidential and a no retaliation policy shall be strictly enforced to protect employees who in good faith report potential violations of company policy or applicable law. Members of the Board should report these matters to the Chief Executive Officer and/or General Counsel of Barr Pharmaceuticals, Inc. or use the Compliance Helpline or Compliance Weblink. Alternatively, if an accounting or auditing matter is involved, concerns or reports of possible violations may be submitted directly to the chair of the Audit Committee of the Board in writing or through the Compliance Helpline or Compliance Weblink. Communications may be submitted anonymously and will be kept confidential, except where disclosure is required by laws, rules or regulations or legal process.

Any waivers of this Code of Conduct for directors and executive officers of Barr may only be made by the Board of Directors or the Audit Committee of the Board after disclosure of all material facts by the individual seeking the waiver and will be promptly disclosed as required by law or stock exchange regulation. Any waivers for other individuals may only be granted by the Global EVP of Human Resources or General Counsel, or their designee, after all requirements are met as specified in Section IV of this document.

Where Code of Conduct violations are determined to exist, appropriate corrective and disciplinary action will be taken, which may include one or more of the following measures, as applicable and in accordance with local legislation other regulations and practice: (i) counseling; (ii) a warning; (iii) a reprimand noted in the employee's personnel file; (iv) probation; (v) change, including reassignment, in job responsibilities, authority and/or title; (vi) temporary suspension, with or without pay; (vii) termination of employment or other relationship with Barr; (viii) removal as a director or officer; (ix) reimbursement of losses or damages resulting from the violation; or (x) referral for criminal prosecution or civil action.

The Company on a periodic basis will continue to add and modify new policies and guidelines as required by changes in law, regulations, or business practices. It is the responsibility of all employees to comply with all policies as issued.