Our Company is committed to the policy that all employees have an obligation to report problems or concerns involving ethical or compliance violations. We have a Corporate Integrity HOTLINE that allows us to seek guidance or report a matter of concern. The toll free number is 1-(800) 838-2552.

All calls to our Corporate Integrity HOTLINE can be made anonymously and without fear of retaliation. Employees are encouraged to provide adequate information in order to assist with further investigation. The calls are not traced and the information is treated in a confidential manner, subject to the limits imposed by law. Careful efforts will be made to ensure that investigations are handled confidentially. The Company has a policy of non-retaliation against any employee or other individual who makes a good faith call to the Corporate Integrity HOTLINE. The term “other individual” refers to consultants, agency temporary employees, customers, providers, vendors and producers, and other entities with whom the Company does business. Any employee who violates this non-retaliation policy will be subject to disciplinary action up to and including termination.

The Corporate Integrity HOTLINE is intended to supplement existing internal communication channels. It is not intended to replace our local management team, Senior Management, or other Corporate Resources. The Corporate Integrity HOTLINE is available when we believe that we have exhausted normal Company channels or feel uncomfortable about bringing an issue to our Supervisor or another Corporate Resource.

The Corporate Integrity HOTLINE is available Monday through Friday, 7:30 a.m. to 5:00 p.m., Central time, excluding corporate holidays.

Questions & Answers

Q. Do I need to identify myself if I call the Corporate Integrity HOTLINE?

A. It is not necessary to identify yourself when you call the Corporate Integrity HOTLINE. You should, however, be prepared to provide enough information about an incident or circumstance to allow the Company to initiate an investigation. It is our policy to preserve the anonymity of callers, subject to the limits imposed by law. You can be assured that all calls will be treated confidentially. However, if you tell others about a Corporate Integrity HOTLINE call, your anonymity may be lost.

Q. Will I be informed if my concern was investigated and/or of the outcome of the investigation?

A. All Corporate Integrity HOTLINE calls are taken seriously. Where appropriate, formal investigations will be conducted discreetly and professionally. However, feedback is often limited by our obligation to protect the rights of all parties involved.

Q. What information should I have to make a report?

A. Because each incident is different, there is no one correct way of documenting it. However, the following ground rules can provide general help in guiding you through the process. These questions should also be used in instances where an oral report is being submitted either by telephone or in person.

1. Describe the situation and the business area involved.

2. Do you know of the situation from your direct observance or did someone tell you about the situation?

3. How did the situation occur? (Was a procedure followed or not followed? Was an instruction given from a Manager or a Supervisor? Did a fellow employee or group of employees decide on an action?)

4. When did the situation occur? (Include dates and an approximate time, period of time, or series of times.)

5. Where did/does the situation occur? (Specify a department, unit, facility, or other location.)

6. Who was/is involved?

7. Has anyone else observed the situation?

8. Who or what might be affected by the situation? (Would it affect internal or external reports? Would another unit be affected? Would customers, members, or providers be affected?)

9. Are there any documents or other evidence to support your report?

10. Have you discussed this matter with anyone else? Have you ever attempted to report this situation before? If yes, to whom and when?

Remember, if you do not understand, or if you have any questions concerning, this Integrity Standard or any other part of the Code, contact your Supervisor, a higher level Supervisor, any of the Corporate Resources or call the Corporate Integrity HOTLINE
(1-(800) 838-2552).

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