Code of Conduct

Integrity Standard - Cooperating with the Government

Policy:
The Company is committed to comply with the laws and regulations that govern the state and federal programs we administer, e.g., the Federal Employee Program, Indian Health Service and Medicare.

We must always show respect for government and regulatory officials. We will cooperate with all reasonable requests for information from government and regulatory agencies. Requests for information other than routine forms must be forwarded to the Legal Department.

All information provided shall be truthful and accurate. We will never take any steps that would impede, obstruct, improperly influence the conclusions of, or affect the integrity or availability of any review or investigation performed by government personnel.

Requests for Information from Government Agencies
We must always provide accurate and complete information to government agencies. We must ensure that information we provide to government agencies includes all material facts necessary to ensure that the information submitted is not misleading.

We must never lie or make false or misleading statements, whether oral or written, to any government official or agency.

We must never attempt to persuade any Company employee, or any other person, to provide false or misleading information to a government official or agency.

We must never destroy or alter any Company document or record in anticipation of or following a request for the document or record by a government agency or court. When a government audit or investigation is imminent or pending, our normal document destruction procedures will be suspended until all documents relevant to the litigation, audit or investigation can be identified and segregated.

If we are approached by any person who identifies himself or herself as a government investigator, we should contact the Legal Department immediately. A representative of the Legal Department will then assist us in following proper procedures for cooperating with the investigation.

Do not feel pressured to talk to a government investigator without first contacting our Legal Department. It is our policy to provide consultation with our Legal Department to any employee who is contacted in connection with a government investigation of the Company.

Gifts to Government and Regulatory Officials
Federal laws prohibit government employees from accepting anything of value, except modest items of food and refreshments. Because of these restrictions, we must not offer or make a gift to a federal employee.

We will abide by all applicable laws, rules and regulations relating to gifts and entertainment of government officials and employees. For additional information, please see the Gifts, Gratuities and Kickbacks Integrity Standard.

Federal Procurement
The Company is subject to the Federal Procurement Integrity Act when bidding on federal contracts. This law dictates certain business conduct for companies seeking to obtain work from the Federal Government. During the bidding process, employees may not: