Code of Conduct

Integrity Standard - Compliance with the Law

Policy:
We will comply with all federal, state, and local laws and regulations. We are each responsible for ensuring our own compliance with laws, regulations and contractual obligations that are applicable to the Company. If we perform services for or work on a government contract, e.g., the Federal Employee Program, Indian Health Service and Medicare, it is our responsibility to know the terms of that contract and all related policies and procedures. Any questions or concerns regarding specific laws, regulations, or any legal issue should be promptly brought to the attention of the Legal Department.

All contracts entered into on behalf of the Company must be executed in accordance with the Company’s then current Execution of Instruments Policy. Individuals executing such contracts are responsible for ensuring that such contracts are consistent with Company policies and are, in the individual’s business judgment, in the best interest of the Company. In addition, according to Company policies and procedures all contracts entered into on behalf of the Company must be reviewed and approved by the Legal Department to ensure compliance with applicable laws and regulations.

Questions & Answers

Q. My Supervisor has directed me to do something that I believe is against the law. I’m afraid that if I don’t do what I am told, my job will be in jeopardy. What should I do?
A. Discuss the situation with your Supervisor to be certain that you both understand the facts of the situation and that he or she is fully aware of your concerns. If that conversation does not resolve the matter to your satisfaction, bring your concern to a higher level Supervisor or to the Legal Department. They will assist you in reaching the right answer. You may also call our Corporate Integrity HOTLINE to express your concern anonymously. Do not jeopardize your job, your co-workers’ jobs or the Company’s future by taking part in what you believe may be an illegal or unethical activity. There are no circumstances where breaking the law would be acceptable to the Company.

Q. I have been working with an outside vendor to finalize a contract. Once legal has signed off on the language of the contract, can I sign the contract on behalf of the Company?
A. All contracts entered into on behalf of the Company must be executed in accordance with the Company’s then current Execution of Instruments Policy. Individuals executing such contracts are responsible for ensuring that such contracts are consistent with Company policies and are, in the individual’s business judgment, in the best interest of the Company.