DATA PRIVACY NOTICE

Introduction

The Teva Integrity Hotline (the "Hotline") is a confidential online reporting system operated by NAVEX, Inc. in the USA ("NAVEX") and provided by Teva to allow people to ask questions and to report suspected violations of company policies or applicable laws and regulations. Using the Hotline is entirely voluntary. You always have the option to report possible violations directly to your manager or supervisor, or to the Legal, Compliance or Human Resources Departments, depending on the nature of the possible violation. If you feel that you are unable to do so, you may use the Hotline to make your report. In certain countries, Teva may only accept reports through the Hotline that relate to financial, accounting, auditing or bribery matters. If your concern regards a matter that, under local law, may not be accepted by Teva through the Hotline, you will need to contact someone in the departments mentioned above to report the matter.

Data Protection Laws

To comply with European and other countries’ data protection legislation we notify you about certain collection and retention practices regarding submitted information containing personal data when you make a report through the Hotline. Because you may either live in, or are reporting about a matter that occurred in a country with such regulations, we ask you to read the terms contained below. If you do not accept these terms please do not use the Hotline but report the matter directly to company management, or to the Legal, Compliance or Human Resources Departments, depending on the nature of the possible violation.

Scope of this Privacy Policy

This privacy policy applies to information we collect through the Hotline or through any follow-up communications with you.

The Hotline is operated by Teva (in your local country) as the data controller (based on the EU General Data Protection Regulation and applicable local data protection legislation) because Teva has the obligation to comply with regulations to prevent and pursue grievances in the areas of corruption and bribery, violation of accounting principles and tax fraud, illegal practice in connection with banks such as money laundering and bank-fraud, falsification of financial documents or balance sheets or insider trading and as well has a vital interest in adherence to its internal policies and preventing and pursuing other legal or compliance violations as the aforesaid. The data in this context is processed for these purposes, on the basis of the legitimate interests of Teva as described in this paragraph.

What Information is collected?

The Hotline generally needs the following information in order to investigate: the reported individuals’ and other involved parties’ name, position/function and contact details; as well as the description of the suspected legal or compliance violation, including all relevant facts and details; information regarding an initiated procedure and the outcome subsequently.

How will the Information be used?

The information you provide will be stored on servers hosted by NAVEX, which acts as data processor. NAVEX is E.U.-U.S. Privacy Shield certified and adheres to these Principles. Unless otherwise required by law, the information within the Hotline database may only be reviewed and used by those individuals who need to access the data to fulfill their job duties in respect to the purposes mentioned above. These individuals may include appropriate Teva employees, external Teva advisors retained to assist in investigating the report, or technical staff at NAVEX.

Teva will evaluate the information you provide and may conduct an investigation. Your cooperation and assistance in that investigation may be necessary. If an investigation indicates that a violation of company policies or applicable laws or regulations has occurred, the local Teva entity will take such action as it determines to be appropriate under the circumstances.

Please be aware that the information you supply about yourself, your colleagues, or any aspect of the company’s operations may result in decisions that affect others. Therefore, we ask that you only provide information that, to the best of your knowledge, is correct and factual. You will not be subject to retaliation from Teva for any report of a suspected legal or compliance violation that is made in good faith, even if it later turns out to be incorrect. Please be aware, however, that knowingly providing false or misleading information will not be tolerated. The information you submit will be treated confidentially.

Please note that because of applicable laws, individuals you identify through the Hotline may be informed about the fact that a report has been made. However, to the extent reasonably possible, Teva will not reveal your name or identity. Depending on local law (such as the GDPR in the European Union), individuals you identify may have the right to respond to or correct information you report.

Any information you submit that is not needed to answer your question or for the investigation of any incident will be deleted or archived, as permitted by local law, works council agreements or individual consent. In addition, once we have responded to your question or completed any investigation, all information you submitted will be deleted or archived as long as necessary to serve the purpose it was collected for and is required by local law, works council agreements or individual consent.

Security

Teva will take appropriate technical, organizational, and legal steps to secure the information you provide. Teva also requires NAVEX to adequately secure your personal data and not use it for any unauthorized purposes. (See the NAVEX, Inc. Privacy Policy for additional information: http://www.navexglobal.com/privacy-statement).

Data recipients

Data will be transferred to TEVA Pharmaceuticals USA Inc., as a controller, other Teva affiliates (when relevant for a particular investigation), NAVEX as a processor, Teva’s legal or other advisors (if assisting with a particular investigation), and government authorities (if relevant/required for a particular investigation). We may share information with national and/or regional authorities when required in accordance with national criminal or other laws. In such cases, we are unable to control their use of any information we share.

International transfers

The information provided will be transferred to and will be stored at TEVA Pharmaceuticals USA Inc., in the USA for purposes of handling and evaluating the questions and reports, initiate corresponding procedures and taking appropriate actions. Teva Pharmaceuticals USA Inc. is E.U.-U.S. Privacy Shield certified and adheres to these Principles. In certain cases (e.g. to investigate an incident) where it is necessary to transfer the provided information to other Teva entities, Teva will comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

NAVEX may transfer some of your information to countries outside your own country, including to the United States. NAVEX is responsible for the processing of personal data it receives, under the E.U.-U.S. Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. NAVEX complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

Your rights

You have the right to request access to and rectification or erasure of your personal data, restriction of or object to processing provided that the data is not accurate or is (no longer) required for the purposes they were collected for.

Further you have the right to lodge a complaint with the competent supervisory authority if relevant in the country where you reside. For a list of the authorities in the European Union, you can find your competent authority here.

In case of further questions please contact Teva’s Data Protection Officer for Europe at EUPrivacy@TevaEU.com. For the USA at USPrivacy@tevapharm.com and for the rest of the world at IL_Privacy.Tevail@teva.co.il.

Contact details

You can find contact details for your responsible data controller in your country here.

My approval

If you have read and understood the notice above, please check the approval box below. You will then be able to submit a report or question on the Hotline. If you do not agree with the above, please do not use the Hotline but report the matter directly to company management, or to the Legal, Compliance or Human Resources Departments, depending on the nature of the possible violation.