CODE OF BUSINESS AND LEGAL CONDUCT

Code of Business & Legal Conduct

This Code of Business and Legal Conduct (“Code of Conduct”) provides the groundwork for each of us to act with the highest level of integrity and in accordance with ethical and legal standards. Compliance is everyone’s responsibility. The Nicklaus Children’s Hospital Compliance Program, which expands upon this Code of Conduct, applies to everyone, including providers, volunteers, students, employees and people who do business with Nicklaus Children’s Hospital.

The Code of Conduct is a critical component of Nicklaus Children’s Hospital’s overall Corporate Compliance Program. We have developed the Code of Conduct to ensure we provide quality patient care, meet our ethical standards and remain committed to our values and guiding behaviors. The Code of Conduct and Nicklaus Children’s Hospital Compliance Program apply to all employees and volunteers, as well as people and businesses who do business with Nicklaus Children’s Hospital, the corporate board of directors, medical staff, students, and contractors that work on behalf of Nicklaus Children’s Hospital (“Nicklaus Children’s Hospital associates”). If you have any questions regarding our expectations of you, of our Code of Conduct or the Nicklaus Children’s Hospital Compliance Program, feel free to contact your supervisor, another member of management at your facility, the Nicklaus Children’s Hospital Chief Ethics and Compliance Officer, or call our Compliance

Hotline at 1-888-323-6248.

Procedures can be found through the

Nicklaus Children’s Hospital is committed to conducting all of our business dealings in compliance with applicable laws and regulations and avoiding any impropriety, dishonesty, or wrongdoing.

We believe adhering to the principals in the Code of Conduct and the Nicklaus Children’s Hospital Compliance Program Hotline number is 1-888-323-6248. You may

will allow us to create and reinforce a corporate culture of embracing compliance and maintain a reputation as a leader in providing innovative, comprehensive, and quality healthcare to our patients. Each of us share in the continuing responsibility to serve our patients and communities.

Nicklaus Children’s Hospital has resources to help you understand expectations related to compliance and to assist you with any

The following resources are always at your disposal, and we urge you to consult them frequently.

1 Policies and Procedures The Nicklaus Children’s Hospital Policies and Nicklaus Children’s Hospital Intranet or the Ethics and Compliance Department.

2 Compliance Program The Nicklaus Children’s Hospital Compliance Program is overseen by the Nicklaus Children’s Hospital Chief Ethics and Compliance Officer

3 Compliance Hotline The Nicklaus Children’s Hospital Compliance questions you might encounter.

call this number at any time to anonymously report a compliance issue or concern.

Remaining silent and failing to report a violation or potential violation may result in disciplinary action, up to and including termination.