Code of Conduct

WHO WE ARE AND WHAT WE STAND FOR

The purpose of the Sababa Health Group (SABABA) Code of Conduct is to reinforce SABABA’s corporate values and to serve as a guide for moral, ethical, and legal behavior. Adherence to the Code of Conduct promotes Sababa’s reputation for integrity and honesty in the community and also ensures that Sababa is compliant with applicable laws, rules, and regulations. For more details, please review the Code of Conduct policy and materials on SABABA’s SharePoint site.

COMPLIANCE OFFICE

Everyone is encouraged to contact the Compliance Office for clarification or direction regarding the Code of Conduct. Supervisors may be contacted for assistance with questions about the Code of Conduct. Please contact the Compliance Office with unresolved questions and concerns about fraud, waste and abuse.

CONTACT THE COMPLIANCE OFFICE

  1. Place a direct phone call or email with the Chief Clinical Officer;
  2. Contact the Compliance Hotline 1-855-662-SAFE (1-855-662-7233) and provide Company ID Number 6464686648;
  3. Visit Safe Hotline at https://safehotline.com and submit a report using Company ID Number 6464686648;
  4. Send a direct email to the Compliance Officer at [email protected]; or,
  5. Email your direct supervisor

DEMONSTRATE HONESTY, INTEGRITY, AND PROFESSIONALISM AT ALL TIMES

We display and promote the highest standards of professional and ethical conduct. We act with the competence, skill, and integrity expected of our professions. We behave with dignity and courtesy toward our patients, clients, coworkers, learners, and others in business-related activities. We are honest, fair, reasonable, and objective in our professional relationships.

ABIDE BY THE CODE OF CONDUCT AND APPLICABLE LAWS, REGULATIONS, POLICIES, AND PROCEDURES

Providing healthcare to a large community is an enormous responsibility. If each of us abides by this Code of Conduct and the laws, rules, regulations, policies, and procedures that apply to us, we will do our part to see that SABABA operates with integrity. If you have questions about the legality or appropriateness of a situation, ask your supervisor or the Compliance Office for clarification.

HONOR PATIENTS’ RIGHTS

As healthcare providers, we have an ethical responsibility to make our patients feel secure in our care and to treat patients respectfully and with dignity. In addition to an ethical responsibility, we have a legal responsibility to comply with all applicable laws and regulations related to patients’ rights. We must also comply with SABABA policies, including policies regarding informed consent, and patient participation in the care plan.

PROVIDE QUALITY CARE

As a healthcare provider, we dedicate ourselves to providing high quality care for our patients. Quality of care is a promise we deliver every day in every aspect of our work. We are committed to following all applicable policies, laws, and licensing / accreditation requirements relating to quality of care and patient safety. We uphold the professional standard of care, report patient safety concerns, and engage in quality improvement activities.

PROVIDE MEDICALLY NECESSARY CARE

At SABABA, we provide care that is medically necessary. Medical necessity requires us to be prudent in the utilization of our resources, being mindful not to over utilize or underutilize the services provided to our patients.

PRESERVE CONFIDENTIALITY AND INFORMATION SECURITY

Protecting confidential information is a SABABA priority. Confidential information includes health information about our patients, information in employee records, and proprietary information about SABABA business. We access confidential information and share it with others only when authorized to do so and for the purpose of doing our job. We follow applicable laws and policies when releasing confidential information and report concerns to appropriate parties. We investigate and report breaches of patient information and take steps to secure our systems from unauthorized access and comply with information security policies.

USE SOCIAL MEDIA AND TECHNOLOGY RESPONSIBLY

SABABA encourages an online and social media culture that complies with the law, internal policies, procedures, and ethical values. SABABA’s workforce may not disclose confidential or proprietary information about SABABA, its patients, or its workforce on social media (including, but not limited to, communications over the Internet, on personal websites or webpages, or in online communities). We do not take or transmit photographs or recordings of patients, visitors or staff in the workplace except as permitted by our policies. Any questions concerning the appropriate use of social media and technology should be directed, as applicable, to your direct supervisor of the Compliance Officer as noted above.

SUPPORT DIVERSITY AND INCLUSION

SABABA supports a culture of diversity and inclusion. We treat everyone with respect. We do not tolerate illegal discrimination against anyone at SABABA, including visitors, patients and fellow workforce members. We do not tolerate conduct that is disrespectful, hostile, intimidating, or harassing.

WORK SAFELY

The health and safety of our patients and our workforce is a SABABA priority. We comply with workplace health and safety laws and report safety concerns. We comply with fitness for duty policies. We maintain a work environment free from violence and disruptive behavior.

COMPETE FAIRLY

SABABA is committed to antitrust compliance and fair competition. We do not make unlawful agreements with competitors about prices or charges, services that we provide, or who to buy from. We do not discuss related matters, such as pricing policies, purchasing practices, costs, salaries, marketing plans, or surveys with those outside of SABABA. We comply with marketing policies and laws related to truth in advertising.

RECORD AND REPORT INFORMATION ACCURATELY

We keep accurate records about our patients, our workforce, clinical activities, and financial transactions. It is the responsibility of each of us, when engaged in recordkeeping on behalf of SABABA (including work force timecards, medical records, and patient bills), to be accurate and honest. For example: • We do not sign another person’s name to documents or share each other’s passwords. • We amend the medical record only in accordance with SABABA policy and applicable law. • We do not fabricate, falsify or plagiarize when proposing, conducting or any activities. • Our financial records conform to applicable accounting principles. We retain documents for the length of time described in our document retention policies.

DOCUMENT, CODE, BILL AND COLLECT APPROPRIATELY

We handle claims for payment of services with integrity to avoid fraud, waste and abuse in healthcare. All SABABA workforce members are expected to comply with federal healthcare program requirements, including, but not limited to, Medicare / Medicaid rules and federal and state False Claims Acts. We bill only for medically necessary services rendered by eligible providers and properly documented and coded. We respond to patient and payer questions concerning charges in an accurate and timely manner. We correct any billing errors of which we have knowledge and refund payments received in error to third party payers and patients, with appropriate documentation. If you become aware of inaccuracies, notify your supervisor so that the error can be corrected. If you see problems with claims that are not being corrected, contact the Compliance Office or Compliance Hotline. We do not do business with excluded individuals or entities.

NO BUSINESS WITH EXCLUDED INDIVIDUALS OR ENTITIES

We expect all individuals and entities associated with SABABA to be appropriately credentialed, licensed and otherwise qualified to perform their duties. SABABA does not do business with, employ, or bill for services rendered by individuals or entities that are excluded or ineligible to participate in federal healthcare programs. SABABA personnel and vendors have a responsibility to report to their supervisor, Human Resources, the Compliance Office (as applicable) if they are excluded, debarred, or otherwise ineligible to participate in healthcare programs.

COOPERATE WITH INQUIRIES, AUDITS, AND INVESTIGATIONS

We cooperate with government inquiries as well as internal and external audits and investigations. When receiving non-routine requests, we consult with the Legal Department or Compliance Office to ensure that requests are handled properly. We are truthful in what we say. We never alter or destroy records in violation of the law or SABABA.

USE RESOURCES RESPONSIBLY

We use SABABA resources responsibly for SABABA business purposes, not for personal gain. We spend SABABA funds wisely, eliminate waste, and control operational costs without compromising patient care. We use physical assets like computers and technology for SABABA business, and we protect those assets from loss, damage, and theft. We don’t waste supplies, equipment, space, or time. We protect intellectual property and respect patents, software licensing, copyright, and other IP agreements.

CONDUCT POLITICAL ACTIVITY AND FUNDRAISING APPROPRIATELY

SABABA respects its workforce members’ rights to participate in or refrain from political and fundraising activities on personal time. Workforce members must follow applicable policies relating to use of SABABA resources for political activity, engagement in political activity while on work time, and similar issues. Workforce members may not inappropriately force, direct or encourage coworkers to support or contribute to a political cause, candidate, or party in violation of the law or applicable policies.

DISCLOSE AND APPROPRIATELY MANAGE CONFLICTS OF INTEREST

We disclose and appropriately manage conflicts of interest. Workforce members must report any actual or potential conflict of interest. Conflicts of interest are situations in which personal considerations may affect, or have the appearance of affecting, our loyalty and ability to fulfill our responsibilities to SABABA. Depending on the circumstances, a “conflict of interest” might include: activities outside of SABABA with a competitor or in violation of our policies, supervising a close relative, purchasing stocks based on confidential information, accepting gifts from a vendor, patient, or fellow provider, or causing SABABA to contract with vendors with whom you have a personal or financial interest. If you have questions about what might be a conflict of interest, review SABABA policies and speak with your supervisor or the Compliance Office.

PROHIBIT BRIBES, KICKBACKS, OR PAYMENT FOR REFERRALS

We do not offer or accept bribes or kickbacks. Bribes and kickbacks are money, gifts, or special treatment given to someone in exchange for a favor. The favor may be many things, from a promise to make patient referrals to a promise to use a particular vendor’s product. We also do not offer or accept “something of value” for patient referrals or services. “Something of value” includes money, services, gifts, entertainment, or anything else of value to the recipient. As this is a highly complex area of the law, workforce members must take special care and promptly refer any questions to the Compliance Office.

PROHIBIT CERTAIN INDUCEMENTS AFFECTING PATIENT CHOICE

The law prohibits SABABA and its workforce from offering certain inducements that may affect a patient’s decision about where to seek care. For instance, it may be illegal to offer copayment waivers, free services, gifts, and other inducements to encourage patients to receive care at SABABA. As this is a highly complex area of the law, work force members must take special care and promptly refer any questions to the Compliance Office.

REPORT COMPLIANCE CONCERNS WITHOUT FEAR OF RETALIATION

Work force members are encouraged to contact the Compliance Office whenever they need clarification or direction regarding Compliance issues (including this Code of Conduct). Work force members are required to report suspected violations of the Code of Conduct, policies, procedures, the law, and regulations to a supervisor, the Compliance Office, or the confidential Compliance Hotline. Retaliation is not permitted against anyone who seeks advice, raises a concern, or reports misconduct in good faith. Such retaliation should be reported immediately to the Compliance Office.