COPC Handbook December 2023 Q4

SECTION I

1.1

Code of Conduct The COPC Code of Conduct is a commitment to perform work in an ethical, honest, moral, and legal manner. Employees are required to perform their job duties and responsibilities in a cooperative and professional manner that reflects favorably on themselves and the Company. All employees are expected to maintain high ethical and work performance standards. Employees are to exercise a mature, courteous, and helpful attitude. Service to our patients, employees, vendors, and others will be professional, thorough, and timely. This means any words or actions which could be construed as harassing, degrading, or offensive will not be tolerated. To ensure orderly operations and an enjoyable work environment, the Company expects employees to follow rules of conduct that will protect the interest and safety of all employees and the organization. All employees must be alert and sensitive to situations that could result in improper, unethical, or illegal conduct. Employees with a compliance or ethics concern have an obligation and responsibility to report the concern to either a Direct Supervisor or the Compliance Hotline. The toll-free Compliance Hotline number

While not intended to be an all-inclusive list, the examples listed below represent behaviors which are considered to be unacceptable in the workplace. Behaviors such as these, as well as other forms of misconduct, may result in disciplinary action, up to and including termination of employment, and in some cases, immediate termination of employment with no notice: ● Fighting or threatening workplace violence ● Unsafe medical practices ● Violation of patient ethics and patient privacy ● Sexual harassment and/or other unlawful or unwelcome harassment ● Workplace bullying ● Theft of any kind (including falsification of timekeeping records) ● Insubordination ● Unprofessional or disrespectful conduct ● Negligence or improper conduct leading to damage of Company owned or patient owned property ● Unauthorized presence on Company property during non-business hours ● Use of Company equipment without prior authorization ● Misrepresentation of personal work history, skills, or training ● Divulging COPC confidential information ● Any misrepresentation of COPC not limited to a patient, a prospective patient, the general public, a vendor, or an employee ● Possession, distribution, sale, transfer, or use of illicit drugs in the workplace, as well as any inappropriate use of legal drugs/substances (including but not limited to prescription medications, over-the-counter medications, alcohol, or marijuana) that results in impairment while working. See Section 4.4 ● Gambling ● Gossiping or spreading rumors about co- workers ● Dishonesty ● Boisterous or disruptive activity in the workplace ● Violation of safety or health policies/rules ● Smoking violations in the workplace in any form, as described in Section 1.15 ● Excessive absenteeism or absence without notice Other forms of misconduct not listed above may also result in disciplinary action, up to and including termination of employment. Civil and/or criminal penalties may also apply depending on the severity of the offense.

General Employment Policies

1.1 Code of Conduct 1.2 Physician Code of Professional Behavior 1.3 “At Will” Employment

1.4 Equal Opportunity Employer 1.5 Immigration Law Compliance 1.6 Americans with Disabilities Act (ADA) and ADA Amendments Act (ADAAA) 1.7 Service Animals 1.8 Anti-Retaliation and Whistleblower 1.9 Conflict of Interest 1.10 Open Door 1.11 Communications & Problem Solving

is (866) 539-5813 and is available 24 hours a day, 7 days a week.

Calls are answered by a third-party vendor with trained staff who will ask questions to obtain the facts and circumstances of the concern, prioritize and categorize the concern, and assign a severity level. A call back date will be provided to obtain follow-up information on the concern. Every reasonable effort will be made to keep employee identity confidential but, despite our best efforts, there may be instances in which caller identity may become known or may have to be revealed to investigate the concern. Employees are responsible for abiding by the Code of Conduct. Managers and Physicians have an additional responsibility to understand the Code of Conduct so they can serve as role models and provide guidance to employees. Violations not only have potential legal and regulatory consequences; they can harm the reputation of COPC.

1.12 Relationships at Work 1.13 Employment of Relatives

1.14 Office Closures (Unplanned and Planned) 1.15 Smoke-Free, Tobacco-Free Workplace

1.16 Break Time for Nursing Parents 1.17 Safety & Accident Rules - OSHA 1.18 Health & First Aid

1.19 Communicable Diseases 1.20 Vaccine Recommendations 1.21 Personal Property: Damaged, Lost, or Stolen 1.22 Solicitations, Distributions, and Posting of Materials

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Questions and concerns can be directed to your immediate supervisor, Human Resources (614) 304-2080 or the Compliance Hotline (866) 539-5813

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