Page 35 - Lupin Employee Handbook and Supplements - July 2018

Lupin Employee Handbook

employee’s job performance for Lupin, is not for a competitor, and does not create a conflict of
interest. Lupin adheres to the highest legal and ethical standards applicable in our business.

Employees are directed to Lupin’s U.S. Code of Business Conduct and Ethics (“the Code of
Conduct”) for more information on employee expectations. It is not possible to specify every
action that might create a conflict of interest. If an employee has any question whether an action
or proposed course of conduct would create a conflict of interest, he or she should immediately
contact his or her supervisor/manager or HR to obtain advice on the issue. The purpose of this
policy is to protect employees from any conflict of interest that might arise.

This policy and Lupin’s Code of Conduct shall supplement and not supersede any previously
signed non-competition agreement by the recipient of this Handbook, the provisions of which, if
there is a conflict with this policy, shall control.

Business Travel and Entertainment Policy

Lupin will reimburse employees for business and client travel for all reasonable and approved
expenses incurred conducting Company business. If applicable, your supervisor/manager must
provide advanced approval of the purpose and timing of all business trips. You should refer to
Lupin’s Travel and Entertainment Policy for further details and requirements related to business
travel, entertainment, and expense reimbursements.

Hiring of Relatives and Employee Fraternization Policy

Lupin will employ qualified individuals regardless of their relationship to any other
employee. However, a conflict of interest may exist where an employee’s family member or
someone else with whom the employee has a close relationship is also an employee of Lupin.
Lupin believes that such relationships can create the appearance of conflicts of interest, can lead
to actual or the appearance of favoritism, bias, unfair treatment, or harassment in the workplace,
and can adversely affect morale, operations, and productivity. Such situations are not prohibited,
but they may call for extra sensitivity to security, confidentiality, and conflicts of interest and, in
accordance with applicable law, Lupin may engage in actions to remove the conflict. It is Lupin’s
general preference that family members not report directly to other family members. Such
situations will be carefully evaluated before being allowed to proceed. If such a reporting
relationship cannot be avoided, prior to making employment decisions (which can include such
things as hiring, assignments, transfers, promotions, or termination) about a family member, an
individual should seek the input of a neutral third party to prevent the perception of a conflict of
interest. In addition, all employees should act professionally and use good judgment in situations
where a relationship may create the appearance of a conflict of interest.

This policy also applies to romantic relationships between employees. Employees who become
family members after their employment begins or who are involved in a romantic relationship may
continue employment as long as it does not create a conflict of interest as described above. If there
is a conflict or potential conflict due to the romantic relationship of two employees, attempts will
be made to find a suitable position with Lupin to which one of the employees will be transferred.
If employees become family members or establish a romantic relationship, Lupin will make
reasonable efforts to assign job duties so as to minimize problems of supervision, safety, security,

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