Employees who report suspected violations of laws and policies demonstrate courage and respect for Cephalon and their fellow employees. You should first go to your supervisor. Management is expected to listen objectively to employee concerns and address issues promptly and effectively. Other resources, if appropriate, include Quality, Legal, Internal Audit, Human Resources, as well as Global Compliance. If you feel these avenues are not available, or you are not sure where to go, you also have the option of using The Hotline to report your concerns.

The Hotline can be accessed in a number of ways:

Contact The Hotline to report concerns about legal violations, ethical problems or other violations of corporate policies or procedures, such as:

• Harassment or discrimination
• Protection of confidential information
• Fraudulent financial reporting
• Environment, health and safety issues
• Violations of sales and marketing policies
• Violations of manufacturing or laboratory policies or procedures
• Drug diversion or abuse
• Insider trading
• Violations of law

Because of specific local laws, in the European Union The Hotline can only be used to report concerns involving finance, account auditing, banking or corruption. A separate but similar Hotline procedure applies to Cephalon’s EU operations and is provided as a supplement to the Standards. Additional copies of the EU procedure can be obtained from the Law Department.

All Hotline telephone calls are handled by trained, safe harbor certified specialists from outside the company. The specialists are located in the United States and will answer your call and listen to your concerns. Translation services are available if you wish to proceed in your native language. Calls to The Hotline are not traced or recorded, and you may choose to remain anonymous or you may give your name and contact information. Leaving contact information can be helpful in expediting an investigation. Should you decide to remain anonymous, at the end of the call, the Hotline specialist will give you a reference number so that you can follow up about your concern at a later date. All Hotline reports are handled with discretion. We do everything practical to protect the confidentiality of those making reports who do not want to disclose their identity and to address concerns in a confidential manner, subject, of course to a legal requirement to disclose to an appropriate governmental authority.

The Hotline specialist will put together a report based on your call, including any personal data that you may have provided. The report will be forwarded to Global Compliance for the sole purpose of having the matter reviewed and conducting any necessary investigation, consistent with local law. Cephalon will conduct fair and appropriate investigations into allegations of misconduct or wrongdoing. Such investigations will be overseen by Global Compliance. We expect employees to participate in and cooperate with internal investigations and to provide truthful and complete information.

The Hotline is optional and employees who choose not to use it will not be penalized. Employees who make reports in good faith will not be penalized, even if the incident reported is not confirmed. Retaliation for such good faith reports is not tolerated and may lead to disciplinary action, up to and including termination. On the other hand, employees who make bad faith reports will be subject to discipline. Cephalon will not provide amnesty to a person who is involved in the wrongdoing about which he or she is making a report or who has ongoing performance problems.