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Concordia is a diverse, international specialty pharmaceutical company focused on generic and legacy pharmaceutical products. Concordia has an international footprint with sales in more than 90 countries, and has a diversified portfolio of more than 200 established, off-patent products. Concordia also markets Photofrin® for the treatment of certain rare forms of cancer. The Company operates out of facilities in Oakville, Ontario and, through its subsidiaries, operates out of facilities in Bridgetown, Barbados; London, England and Mumbai, India. Concordia is a public company; its common shares trade on the Toronto Stock Exchange and on the NASDAQ Global Select Market. The purpose of this Policy is to provide directors, management, employees and others considered to have a special relationship1 (each, a “Concordia Person”) with Concordia direction on: (a) the process and restrictions for public disclosure made by Concordia, (b) restrictions on trading securities of Concordia, and (c) on the use and handling of confidential information of Concordia. References to Concordia in this Policy include Concordia International Corp. and all of its subsidiary entities, including the businesses operated by those entities.