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PARKLAND HEALTH &HOSPITAL SYSTEMCODE OF CONDUCT & ETHICSParkland Code of Conduct & Ethics-April 2012

TABLE OF CONTENTSINTRODUCTION…………………………………………………….................... 3OUR VISION, MISSION AND GUIDING PRINCIPLES…….............................. 4QUALITY OF CARE AND PATIENT RIGHTS…………………….................... 5HEALTH AND SAFETY……………………………………………………......... 6CONFIDENTIALITY OF PROTECTED HEALTH INFORMATION.................. 7WORKPLACE ENVIRONMENT……………………………………………....... 8PROTECTION AND USE OF INFORMATION, PROPERTY ANDASSETS…………………………………………………………………………… 10CONFLICTS OF INTEREST................................................................................... 11LEGAL AND REGULATORY COMPLIANCE……………………………… 12BILLING AND CODING COMPLIANCE………………………………………. 15CLINICAL RESEARCH COMPLIANCE……………………………………....... 17RELATIONSHIPS WITH PHYSICIANS AND OTHER PROVIDERS………… 18RESPONSIBILITIES FOR REPORTING CONCERNS AND VIOLATIONS….. 19 How To Report Integrity Line Non-Retaliation Corrective/Disciplinary ActionParkland Code of Conduct & Ethics-April 20122

INTRODUCTIONParkland Health & Hospital System’s (“Parkland’s”) commitment to compliance andethics is an essential component of our core business practices and is critical to thesuccess of our mission. Parkland has established a comprehensive, values-basedCompliance & Ethics Program to support our mission and to demonstrate Parkland’s duediligence in promoting an organizational culture that encourages legal and ethicalconduct. The goals of the Compliance & Ethics Program are to:Foster a culture of integrity, accountability and ethical behavior throughout theorganization;Implement processes and procedures that promote prevention, detection andcorrection of conduct or practices that are illegal or unethical;Establish an environment that encourages employees to report ethical concernswithout fear of retaliation;Identify and address Parkland’s primary compliance risks;Establish effective internal controls that promote adherence to applicablefederal and state laws and regulations; andMaintain ethical and transparent business practices thus reassuring the public’strust and confidence in Parkland.The Parkland Code of Conduct & Ethics (“Code”) is the foundation of our Compliance &Ethics Program and outlines the standards by which we will carry out our daily workactivities at Parkland.The standards set forth in the Code apply to all members of the Board of Managers,officers, employees, members of the medical staff, volunteers, contractors, vendors,agents and others conducting business with, or on behalf of, Parkland and will be appliedconsistently at all levels of the organization. The Code is also designed to include theoperations of the Parkland Community Health Plan, Parkland Foundation, and otherParkland affiliates.Because the Code of Conduct & Ethics rests on our mission, vision, and guidingprinciples, it is an integral part of our daily activities and sets the tone for our personaland business behavior. Upholding the standards set forth in the Code of Conduct &Ethics is critical to preserving the public’s trust and confidence in Parkland.Parkland Code of Conduct & Ethics-April 20123

MISSIONDedicated to the health and well-being of individuals and communitiesentrusted to our care.VISIONBy our actions, we will define the standards of excellence for publicacademic health systems.GUIDING PRINCIPLESOur values and principles reflect our shared responsibility to achieve healthcare excellence for our patients and communities.CompassionWe will provide service in a spirit of empathy, love, and concern.IntegrityWe will be honest, trustworthy, authentic, humble, and transparent in all of ourrelationships. We will demonstrate devotion to duty and to the service of others.RespectWe will treat everyone fairly in recognition of their intrinsic worth.CollaborationWe will work together with our patients and partners.LeadershipWe will create a servant-led environment.ExcellenceWe will provide high standards of service and performance.StewardshipWe will manage resources responsibly and bring value to patients and taxpayers.Parkland Code of Conduct & Ethics-April 20124

QUALITY OF CARE AND PATIENT RIGHTSStandard of Conduct: We are committed to providing high quality health careand services to our patients, their families, visitors, and the community. Allpatients have the right to safe care, quality services, transparency, and privacyas outlined in our Patient Rights and Responsibilities form.We will treat our patients with dignity and respect at all times.We will listen to our patients, families, and visitors to understand any concerns orcomplaints and will involve patients in the decision- making process about theircare.We will recognize the right of our patients to receive appropriate servicesprovided by competent individuals in an efficient, cost effective, and safe manner.We will provide services that are based on current standards of practice.We will continually monitor the clinical quality of our services and strive toimprove the quality of the services provided.We will protect our patients from real or perceived mental, physical, sexual orverbal abuse, neglect, or exploitation from anyone, including staff, other patients,visitors or family members. We will immediately report any alleged abuse,neglect or exploitation to a supervisor.We will respond to patient questions, concerns, and needs in a timely andsensitive manner.We will respond to patients and/or families who are involved in or witnessintimidating and/or disruptive behaviors and will thank them for sharing theirconcerns.We will apply our admission, treatment, transfer, and discharge policies to allpatients based upon identified patient needs, our statutory mission, andappropriate business practices (including guidelines for payment and financialclassification).We will provide treatment and medical services without discrimination based onrace, age, religion, national origin, sex, sexual orientation, or disability.We will maintain licensure and credentialing standards to further the provision ofclinical services by properly trained and experienced practitioners.Parkland Code of Conduct & Ethics-April 20125

HEALTH AND SAFETYStandard of Conduct: We are committed to promoting a culture of safety and assuringquality for the health and safety of our patients and their families, visitors, employees,physicians, and other service providers.We will take all reasonable precautions and will comply with and abide by applicableenvironmental, health, and safety laws and regulations and Parkland policy tomaintain a safe and secure environment.We will encourage patients and their families to report their observations andcomplaints of unsafe conditions to a Supervisor and/or a Patient Advocate.We will strive to provide an environment for all individuals that is free from any formof verbal, physical, sexual or other unlawful harassment or intimidation.We will quickly and efficiently respond to patients’ safety concerns, questions andneeds.We are committed to providing a safe work environment and will implement andmonitor policies and procedures for workplace safety compliant with federal and statesafety laws, regulations, and workplace safety directives.We will strive to provide an environment that is free from violence. Unauthorizedweapons of any kind are strictly prohibited.We will promptly report any accidents involving injury to an employee, physician, orother service provider, applicable third party or visitor through the event reportingprocess.We will alert the appropriate departments and personnel if unsafe conditions orpractices are observed in the work environment.We will adhere to all regulations and procedures for disposing of medical waste andhazardous material.We will promptly report all spills or accidents involving medical waste or hazardousmaterials to a supervisor and take immediate action to help prevent harm and/orfurther damage.We will immediately advise our supervisor if, as a result of work, we are injured orcontract an occupational illness.We will safely store, secure, and count all drugs and pharmaceuticals. Missing ordiverted drugs will be promptly reported to the appropriate supervisor.We will promptly report incidents that compromise our patients’ safety utilizing thePatient Safety Network (PSN).Parkland Code of Conduct & Ethics-April 20126

CONFIDENTIALITY OF PROTECTED HEALTH INFORMATIONStandard of Conduct: We are committed to honoring our patients’ right forProtected Health Information (PHI) to be kept confidential and will take theappropriate measures to protect the privacy and security of our patients’ PHI.We will safeguard our patients’ PHI in a manner that is reasonable and appropriate toavoid intentional or unintentional use or disclosure.We will respect the privacy of our patients and abide by all applicable laws andregulations and Parkland policy to protect the PHI of our patients.We will limit the amount of PHI (written, spoken or electronic) to the minimumamount needed to accomplish the intended purpose when accessing, using, disclosingor requesting PHI.We will limit access to PHI based strictly on a legitimate clinical or business needthat is appropriate for the role or function performed in the organization.We will not reveal or discuss patient-related information except with health carepersonnel involved in their care, payors and others authorized to review patientinformation in the course of treatment, payment, and/or healthcare operations.We will release PHI and patient records in accordance with applicable laws andregulations and Parkland policy.We will obtain properly completed authorization forms prior to disclosing PHI forany request outside of normal treatment, payment, and/or healthcare operationspurposes.We will protect the privacy and security of patient medical, billing, and claimsinformation, and other PHI through sufficient and reasonable physical, technical, andadministrative measures to prevent unauthorized access to or use or disclosure ofpatient information.We will provide access to medical, billing, and claims information for our patientsand their legal representatives as required by law.We will seek advice when in doubt about privacy and confidentiality requirementssurrounding PHI from our supervisor or the Parkland Privacy Officer.Parkland Code of Conduct & Ethics-April 20127

WORKPLACE ENVIRONMENTStandard of Conduct: We recognize that accomplishing Parkland’s mission isdependent upon our people, a team that includes many diverse individuals withvaried skills and competencies. Every member of the team is important.We will treat everyone with fairness, dignity and respect.We will engage in human resources practices that promote personal andprofessional advancement.We will hold each other accountable for modeling desirable behaviors whichinclude, but are not limited to: maintaining high levels of professionalism; respecting all patients, family members, staff and visitors; working as a team member; communicating openly and honestly; maintaining patient confidentiality; and reporting patient safety concerns promptly.We will provide equal employment opportunities to employees and applicants foremployment and require that all employment actions be made without regard torace, color, religion, sex, national origin, marital status, political belief, age (40 orover), veteran status, sexual orientation or disability in accordance with applicablelaws and regulations.We will comply with all applicable laws, regulations and policies and proceduresthat govern employment matters.We will prohibit unauthorized sales and solicitation of orders for any type ofproduct or service to anyone on Parkland premises unless specifically authorizedby Parkland.We will promote diversity with respect to individuals with disabilities and willmake reasonable accommodations to any individual, as required by law.We will immediately self-disclose any and all felony and misdemeanorconvictions (excluding Class C misdemeanor traffic law violations), includingthose for which we received probation.We will follow all laws and policies regarding the manufacture, sale, possession,distribution, or use of illegal drugs or alcohol, which are strictly prohibited atParkland. Reporting to work while under the influence of illegal drugs or alcoholwill not be tolerated.We will strive to ensure that our actions contribute to performing our Parklandduties in an ethical and effective manner.Parkland Code of Conduct & Ethics-April 20128

We will fully investigate reports of unacceptable or disruptive behavior in thework environment. If a report of such behavior is substantiated we will apply theprovisions of the applicable Human Resources Corrective Action Procedure(s) orthe Medical Staff Unprofessional and Disruptive Conduct Procedure(s).Parkland Code of Conduct & Ethics-April 20129

PROTECTION AND USE OF INFORMATION, PROPERTY, ANDASSETSStandard of Conduct: We are committed to protecting Parkland information andother property against loss, theft, destruction, and misuse.We will correctly use and care for all property and equipment entrusted to us.We will appropriately maintain inventory and keep all supplies secure.We will comply with software licensing agreements.We will prohibit the making of unauthorized copies of computer software or theuse of personal software on Parkland computer equipment.We will safeguard and protect confidential Parkland information and not use orreveal such information except in the proper performance of our duties and inaccordance with applicable laws and regulations and Parkland policy.We will maintain all information, whether medical, financial or business, inaccordance with all applicable laws and regulations and organizational policies.We will not falsify or inappropriately alter information on any record ordocument.We will establish retention periods and protocols for business, financial, andpatient records in our system in accordance with Parkland’s Record RetentionGuidelines.We will promote the accurate, detailed, and complete documentation of allbusiness, financial, and patient transactions.We will control and monitor access to Parkland’s communications systems,electronic mail, Internet access and voicemail to ensure that such systems areaccessed appropriately and used in accordance with Parkland policy.We understand that the use of technology to send offensive, discriminatory, orharassing messages is prohibited.We will not knowingly communicate or transfer any information or documents toany unauthorized persons.We will safeguard the personal and human resources information of ouremployees and information retained within the human resources system asrequired by law.Parkland Code of Conduct & Ethics-April 201210

CONFLICTS OF INTERESTStandard of Conduct: We are committed to conducting business in an honestand fair manner and in the best interest of Parkland and our patients. A conflictof interest may occur if outside activities or personal interests influence orappear to influence an individual’s ability to make objective decisions in thecourse of job responsibilities. We expect our colleagues to avoid any activitiesthat may involve (or may appear to involve) a conflict of interest.We will avoid conflicts of interest between our own private interests and ourParkland duties.We will not use our position, or knowledge gained in our position, in any way thatwe could receive personal benefit.We, or any member of our family, will not receive any substantial specialpreferences from a person or organization that, to the best of our knowledge, doesor wants to do business with Parkland, or is a competitor of Parkland.We will make decisions about the purchase of outside services and goods basedon the supplier’s ability to best satisfy Parkland’s needs and not based on personalrelationships.We will not offer, accept, or provide personal gifts or favors, such as tips, meals,transportation, or entertainment that create a conflict of interest.We will direct donations, grants, or contributions (whether in cash or non-cash) tothe Parkland Foundation to assure that gifts are properly received, recorded andacknowledged in accordance with tax law.We may not accept one or more gifts, benefits, entertainment, or other favors witha value in excess of $250 in a 12-month period, from any current or prospectivesupplier, vendor, or organization with which, to the best of our knowledge,Parkland does business in any regard. Entertainment and routine business mealsthat are part of a routine business meeting are not included in this limit, but theymust be reasonable and in moderation.We will maintain unbiased relationships with actual and potential Parklandvendors and contractors.We will exercise good faith and fair dealing in all transactions that involve ourresponsibilities to Parkland.We will not use any Parkland assets or resources for personal gain.We will not use any proprietary or non-public information acquired as a result ofa relationship with Parkland for personal gain or for the benefit of anotherbusiness opportunity.Parkland Code of Conduct & Ethics-April 201211

We will not have a business relationship with a family member without followingapplicable Parkland policy.We will not accept gifts from patients or their families that exceed nominal value($50) and will never accept money or cash equivalents from patients or theirfamilies.We will not engage in any outside employment, consultation, or other activities,which might compromise Parkland’s strategic position or affect our objectivity,independence of judgment, or conduct in carrying out our duties andresponsibilities to Parkland.We will immediately report actual or perceived conflicts of interest to oursupervisor or the Office of Corporate Compliance & Ethics.Parkland Code of Conduct & Ethics-April 201212

LEGAL AND REGULATORY COMPLIANCEStandard of Conduct: We are committed to upholding high standards ofbusiness and professional ethics and integrity and will continuously andvigorously promote full compliance with applicable laws and regulations andParkland policy.We will conduct our activities in compliance with all applicable laws andregulations and Parkland policies and procedures.We will continuously study our legal obligations and create policies andprocedures that facilitate compliance with such legal obligations.We will promptly report to management, the Compliance Officer or the ParklandIntegrity Line any potential violation of law, regulation, or Parkland policy.We will not tolerate any retaliation by Parkland employees against an individual,who, in good faith, reports a suspected violation or acts as a whistleblower inaccordance with the False Claims Act or other law.We will implement policies for all employees and any contractor or agent ofParkland involved in providing patient care pertaining to the Federal False ClaimsAct (FCA), including the administrative remedies for knowingly submitting falseclaims and statements, any State laws pertaining to civil or criminal penalties forfalse claims and statements, and whistleblower protections under such laws.We will expect our colleagues to understand their basic legal obligations and jobresponsibilities.We will accept patient referrals and admissions based on the patient’s clinicalneeds, our statutory mission, appropriate business practices (including guidelinesfor payment and financial classification), and our ability to render the neededservices.We will not offer, provide, solicit, or accept inducements, kickbacks, bribes,rebates, or anything else of value with the intent to influence the referrals ofpatients.We will not provide inducements for patients to access services payable by agovernment health care program (e.g., Medicare, Medicaid, etc.).We will require that all compensation arrangements or other agreements withindividuals or organizations that may be possible referral sources (e.g.,physicians, etc.) be in writing, kept current and approved through the appropriateprocess.Parkland Code of Conduct & Ethics-April 201213

We will engage in open and fair competition and marketing practices.We will not knowingly hire or contract with individuals/entities who have beensanctioned by the Office of Inspector General of the U.S. Department of Healthand Human Services ("OIG") or appear on any of the following lists: OIG List ofExcluded Individuals/Entities (“LEIE”), the List of Excluded Individuals/Entitiesby the Texas Office of Inspector General, the General Services AdministrationExcluded Parties List System (“EPLS”), and the U.S. Treasury Office of ForeignAssets Control Specially Designated Nationals (“SDN”) List.We will ensure that all employees, medical staff, and applicable third parties whoare providers of patient services are properly licensed and trained prior toadministering patient care.We will comply with the Emergency Medical Treatment and Active Labor Act("EMTALA") and provide an appropriate medical screening examination to allthose who seek emergency treatment.We will ensure that all marketing, advertising, and sales communications areclear, correct, accurate, and compliant with the patient privacy regulationscontained in the Health Insurance Portability and Accountability Act of 1996(HIPAA).We will provide information to all employees, agents, and contractors involved inthe care of patients with information regarding the Federal and State False ClaimsActs.We will cooperate with internal investigations, audits, reviews or directions fromParkland’s legal counsel in connection with lawsuits or governmentalinvestigative proceedings.Parkland Code of Conduct & Ethics-April 201214

BILLING AND CODING COMPLIANCEStandard of Conduct: We are committed to fair and accurate billing that is inaccordance with all applicable federal and state laws, regulations, and Parklandpolicy.We will comply with the False Claims Act which prohibits “knowingly” makingfalse claims for payment to the federal government. “Knowingly” means havingactual knowledge that the claim is false, acting in deliberate ignorance as towhether the claim is true or false, or recklessly disregarding the truth or falsity ofthe information.We understand that all claims for services submitted to any insurance program orpayer, Medicare, Medicaid, or other government funded health care programshave to be accurate and correctly identify and document the services ordered andperformed.We will bill only for services actually provided and documented in the patient’smedical records.We will promote compliance with laws governing the submission and review ofbills for our services and will address billing inquiries in an honest and forthrightmanner.We will charge for all health care services provided and will require payment ofinsurance co-payments or deductibles and not routinely waive these fees.We will use systematic methods for analyzing the payments we receive to identifyany overpayments in a timely manner.If we identify an overpayment, the retention of which could constitute a falseclaim, we will promptly report and return it.We will assign diagnostic, procedural, and billing codes that accurately reflect theservices that were provided.We will periodically review coding practices and policies, including softwareedits, to facilitate compliance with all applicable federal, state, and private payerhealth care program requirements.We will investigate inaccurate billings and payments to determine whetherchanges to current protocol or other remedial steps are necessary.We will respond to questions and complaints related to a patient’s bill in a directand honest manner.Parkland Code of Conduct & Ethics-April 201215

We will review cost reports to be filed with the federal health care programs foraccuracy, completeness, and compliance with applicable laws and regulations andParkland policy.We will implement documentation systems sufficient to create and maintaincomplete and accurate documentation of services provided.We will prohibit the premature destruction or alteration of any document inresponse to, or in anticipation of, a request for those documents by anygovernment agency or court.Parkland Code of Conduct & Ethics-April 201216

CLINICAL RESEARCH COMPLIANCEStandard of Conduct: We will undertake scientifically meritorious clinical research,adhere to the ethical principles of respect for persons, beneficence and justice in allresearch involving human subjects and promote full compliance with applicable laws,regulations and Parkland policy.We will support clinical research that we expect to benefit the community weserve, provided such anticipated benefits are commensurate with any foreseeablerisks to our patients.We will safeguard the health, welfare, privacy, and dignity of our patients whoparticipate in clinical research.We understand our patients who participate in clinical research are entitled to allof the rights and protections afforded to our patients generally.We will comply with federal regulations and ethical standards as outlined in ourFederalwide Assurance for the conduct of research involving human subjects,regardless of funding source or “exempt” status under the regulations governingthe protection of human subjects in research.We expect our colleagues who engage in clinical research to be qualified for theirroles, to be credentialed at Parkland, to understand and abide by human subjectsprotection principles and good clinical practices for research, and to adhere toapplicable laws and regulations and Parkland policy.We recognize that research participants are entitled to special protections underthe HIPAA Privacy Rule and will enforce compliance with those regulations.We will not engage in any financial relationship or other activity that mayinfluence or appear to influence our ability to protect human subjects orcompromise the scientific validity of research results.We will investigate and respond promptly to concerns raised by or involvingresearch participants and to allegations of non-compliance or unethical conduct byor involving research staff.We will monitor and update our billing practices as necessary for research toavoid and detect false or fraudulent claims.We will not knowingly allow any individual who appears on the FDA DebarmentList, is disqualified or restricted as a clinical investigator by the FDA, or appearson the Public Health Service Administrative Actions List to conduct research atParkland.Parkland Code of Conduct & Ethics-April 201217

RELATIONSHIPS WITH PHYSICIANS AND OTHER PROVIDERSStandard of Conduct: We will monitor our business dealings to structurerelationships in ways that satisfy the needs of the community and comply withall applicable laws and regulations and Parkland policy.We will maintain relationships with physicians and other referral sources basedonly on the needs of our community and consistent with the furtherance of ourmission.We will treat referral sources fairly and consistently and will not provideremuneration that could be considered payment for referrals.We will implement policies and procedures that require fair market valuedeterminations for services rendered by referral sources and for services renderedby Parkland.We will implement procedures to require all agreements with referral sources tobe reduced to writing and reviewed and approved as appropriate under applicablelaws and regulations and Parkland policy.We will train the appropriate personnel on the laws and regulations governing thereferral of patients, other legal restrictions on Parkland business transactions, andthe penalties for violations of such laws.Parkland Code of Conduct & Ethics-April 201218

RESPONSIBILITIES FOR REPORTING CONCERNS ANDVIOLATIONSAll Parkland employees must be familiar with this Code of Conduct & Ethics and besensitive to any situation that could potentially lead to actions that might conflict with theCode of Conduct & Ethics. All employees have the duty and responsibility for reportingperceived, actual, or potential violations of laws and regulations, Parkland policy, or theCode of Conduct & Ethics.Parkland is committed to providing a means of raising questions and concerns andreporting any conduct that is suspected to be in violation of laws, regulations, Parklandpolicy, or the Code. There may be times when you are unsure whether an activity or asituation is unethical or illegal. If you are not sure, pursue it until you are confident thatit is either resolved or that the right person in Parkland knows the facts and has takenaction. A delay on your part could be serious for you, for others, and for Parkland.How to report concernsYou are encouraged to use the following steps to resolve any questions or concerns youmay have:1. Discuss the question or concern with your direct supervisor. Give yoursupervisor a chance to solve the problem. He or she is most familiar with thelaws, regulations, and policies that relate to your work.2. If you are not comfortable with talking to your supervisor or feel you did notreceive an adequate response, contact your supervisor’s manager or anothermember of the management team.3. Contact your Human Resources (“HR”) Business Partner or another memberof the HR Division.4. Contact the Parkland Office of Corporate Compliance & Ethics at (214) 590-1171.5. Call the toll free Parkland Integrity Line at (800) 351-0093 or file an IntegrityLine Report online at www.parklandintegrityline.ethicspoint.com. The ChiefCompliance Officer will review and address all reports made to the IntegrityLine.The following list, while not exhaustive, describes the type of concerns and questions thatyou should raise: Improper billing or coding of patient accounts The submission of false, inaccurate, or questionable claims to Medicare,Medicaid, or any other payer Falsification of documentation Destruction of evidence during an investigation or related to actual oranticipated litigation The provision or acceptance of payments, discounts, or gifts in exchange forreferrals of patients Suspected or actual breaches of patient privacy and security or identity theft Situations that could raise conflict of interest concerns Retaliation for reporting compliance and ethics concernsParkland Code of Conduct & Ethics-April 201219

There are words and phrases that raise “red flags” about potential problems and shouldsend a warning signal to you. The following are examples of such words and phrases: “Well, maybe just this once.” “Everyone does it.” “No one will ever know.” “Shred that document -- no problem.” “No one will get hurt.”Integrity LineAlthough we encourage use of the reporting process outlined above, we understand thatthere may be some circumstances when you may not feel comfortable reporting concernsin this manner or the concern cannot be addressed through the normal reportingprocesses. It is for such circumstances that we have established the Parkland IntegrityLine.To ensure that you are not discouraged from filing a report, we have partnered with athird-party vendor to provide a comprehensive and confidential means of reportingpotential concerns and violations. The operators of the Integrity Line are trained to assistyou in reporting questions and concerns. The toll-free telephone number for theParkland Integrity Line is (800) 351-0093 and the web address iswww.parklandintegrityline.ethicspoint.com.Reports made to the Integrity Line will not be traced or recorded. You have the option toreport anonymously, if desired, however, doing so may limit a full investigation. Havingthe contact information of the reporter is very helpful in addressing most concerns. If youprovide your name and contact information, your identity will be protected to the extentallowed by law and to the extent that it does not hinder the investigation. Reports made ingood faith to the Integrity Line will not result in disciplinary action or retaliation againstyou.All reports will be forwarded to the Office of Corporate Compliance & Ethics forinvestigation. Each matter will be fully investigated on the merits and, depending on theresults of the investigation, appropriate action(s) will be taken.Non-Retaliation PolicyParkland recognizes that a critical aspect of its Compliance & Ethics Program is theestablishment of a culture that promotes prevention, detection, and resolution of instancesthat do not conform to federal, state and private payer healthcare program requirements,as well as the organization’s ethical and business policies. To promote this culture, astrict non-retaliation policy has been established to protect employees who reportconcerns in good-faith from retaliation.No disciplinary action or retaliation will be taken against you when you report in goodfaith a perceived issue, problem, concern, or violation (by others) to management, HumanResources, the Office of Corporate Compliance & Ethics, the Parkland Integrity Line, orParkland Code of Conduct & Ethics-April 201220

act as a whistleblower pursuant to the Federal False Claims Act or other law. In “goodfaith” means an employee actually believes that the information reported is true.The False Claims Act provides protection against retaliation for whistleblowers that aredischarged, demoted, suspended, threatened, harassed, or in any other mannerdiscriminated against in the terms and conditions of employment by his or her employerin retaliation for filing a False Claims Act action.You have the right to be treated fairly and with respect, and Parkland will strive to ensurethat you are treated that way. Though we have policies to protect good-faith reporting,you will not be exempt from the consequences of your own misconduct by reporting anissue. However, self-reporting may be taken into consideration when determining theappropriate course of action.Corrective/Disciplinary ActionAny employee who violates any law, regulation, Parkland policy, or the Code of Conduct& Ethics will be subject to corrective or disciplinary action under Human ResourcesPolicies and the Parkland Compliance & Ethics Program up to and including terminationfrom employment, if warranted.You should be aware that certain actions prohibited by Parkland policy also might violatelaws resulting in personal criminal or civil prosecution.Parkland Code of Conduct & Ethics-April 201221