Code of Conduct

When the Government is Our Client

In the course of our employment we may directly or indirectly perform services or work related to one or more government contracts, e.g., Federal Employee Program, Indian Health Service and Medicare. When the government is our client, there are additional requirements that we must adhere to. When we act as a government contractor or subcontractor, we have a special obligation not only to the government and the beneficiaries of those government programs but also to the public at large to ensure that we perform with the highest degree of integrity. Specifically, it is our responsibility to know the terms of the government contract(s) that we are performing services for or are working on and all of the policies and procedures related to those contracts. We may also be required to sign certifications, either internal or to the government, regarding the accuracy of information or the Company’s performance under the contracts. If we have any doubt regarding any aspect of the Company’s performance under any government contract, it is our duty to come forward immediately.

The unique nature of doing business with the government implicates particular statutes and regulations that do not normally apply to commercial transactions. There are also a number of laws that apply to government agencies and who they do business with so that the legal obligations of these agencies “flow down” to the Company as a contractor or subcontractor. Below is a brief general summary of what we must do and what we must not do under some of these statutes and flow down provisions of our government contracts, e.g., Federal Employee Program, Indian Health Service and Medicare.

When Bidding on a Government Contract

We Must	We Must Not
Submit pricing data that contains all the facts that a prudent buyer and seller would reasonably expect to affect price Truth In Negotiations Act	Offer or give gifts to any procurement official or make offers or promises of future employment to government employees that are involved in the bid Federal Procurement Integrity Act
	Obtain non-public bid or proposal information such as cost or price data, proprietary information about techniques or indirect costs, etc., or agency source information prior to the award of the contract Federal Procurement Integrity Act
See also "kickbacks" below

In Performance of our Government Contracts

We Must	We Must Not
Obtain the necessary written approvals prior to information being used for any purpose other than as allowed under our government contracts and provide assurances that personal information about individuals collected and disclosed is limited to that which is legally authorized and necessary The Privacy Act of 1974	Offer or accept any form of kickback, i.e., money, fee, commission, credit, gift, gratuity, thing of value or compensation for the purpose of improperly obtaining or rewarding favorable treatment including obtaining unwarranted waivers of deadlines and acceptance of non-conforming goods in connection with a prime contract or subcontract. Anti-Kickback Act
Protect the confidentiality and do not disclose beneficiary records regarding any assistance that such beneficiary may have received from the government related to the treatment, diagnosis, or prognosis of substance abuse The Alcohol, Drug Abuse & Mental Health Admin. Reorganization Act	With actual knowledge of falsity, reckless disregard for the truth or falsity, or deliberate ignorance of the truth or falsity, submit false or fraudulent claims for payment False Claims Act
Honor appropriate requests from the public for government records that we create and maintain Freedom of Information Act & Electronic Freedom of information Act Amendments of 1996	Make any false statements or representations False Statements Accountability Act
Provide required evaluations and reports regarding our internal accounting and administrative controls including compliance with the law, reasonable assurance and safeguards, etc. Federal Managers Financial Integrity Act of 1982	Hire or do business with individuals or entities that have been debarred or excluded from participation in federal health care programs Social Security Act, HIPAA & Balanced Budget Act of 1997

In Regards to Our Workplace

We Must	We Must Not
Maintain a drug-free workplace by prohibiting the manufacture, distribution, dispensation, possession or use of narcotics, drugs or other controlled substances in the workplace or while conducting Company business Drug-Free Workplace Act of 1988	Discriminate against individuals in the terms and conditions of employment based on race, color, religion, sex, national origin or age Civil Rights Act of 1964 (Title VII) Age Discrimination Act of1975
Take affirmative action to ensure that applicants are employed, and that employees are treated during employment, without regard to their race, color, religion, sex or national origin and identify and eliminate impediments to equal employment opportunities Executive Order 11246 41 CFR Part 60-2 Federal Acquisition Regulations Subpart 22.8	Discriminate against individuals in the terms and conditions of employment based on disability or perceived disability Americans with Disability Act and Rehabilitation Act of 1973
Take affirmative action to ensure that veterans and disabled veterans are provided equal employment opportunities Affirmative Action for Disabled Veterans and Veterans of the Vietnam Era	Offer to hire, hire or otherwise do business with certain current or former government employees

Failure to comply with these laws, the terms of our government contracts and Company policies and procedures can: