The Health Plan expects all employees (including executive, management, and support employees) to conduct all activities

with the utmost ethical integrity and in compliance with all applicable laws and regulations. These Standards of Conduct include a code of ethics and are designed to guide employees in their daily business and workplace operations. All employees of the Health Plan shall adhere to the laws, rules, regulations and policies of applicable governmental authorities and these Standards of Conduct. Failure to do so may be grounds for disciplinary action, up to and including termination of employment.

STANDARDS OF CONDUCT
Accuracy of Records. All records, whether of a medical, operational, or financial nature, should be maintained in accordance with applicable laws and policies. No false or misleading entries shall be made in any way in any of the Health Plans books, records or accounts for any reason. Making any false statement in a medical record that is used to support billing of medical services is considered criminal fraud. Billings to third-party payors (government and private insurance payors) and federal sponsored research are examples of records that must be accurate and conform to appropriate laws and regulations. Authority to Act on behalf of the Health Plan. All employees should be aware of the limitations on their authority to act on behalf of the Health Plan and should not take any action that exceeds those limits. No one is permitted to sign any document on behalf of the Health Plan or in any other way represent or exercise authority on behalf of the Health Plan, unless specifically authorized to do so. Only individuals expressly authorized by the CEO of the Health Plan may enter into contracts or agreements either oral or written on behalf of the Health Plan. No person may sign a contract unless expressly authorized to do so in writing by the Board of Directors. No employees of the Health Plan may expend funds for any purchase unless the person is authorized to make such purchase in accordance with the Health Plan approved policies and procedures for doing so. Claims Reimbursement. All claims for reimbursement made by or on behalf of the Health Plan shall adhere to applicable laws, regulations, and the Health Plan Board of Director approved policies and procedures. Employees shall follow all legal and regulatory guidelines for claims reimbursement for services provided by contracted providers. The Health Plan shall collect only those amounts to which the Health Plan is entitled, and promptly refund amounts billed and/or collected in error. Computer Information Security. Computer passwords should be considered highly confidential. Employees should never disclose computer passwords to anyone other than those individuals in the Health Plan that have official capacity to access employee passwords. Furthermore, employees should not write or otherwise document passwords in a place that is accessible by others. Computer Software. Employees who use software licensed to the Health Plan or an entity owned by the Health Plan must abide by applicable software license agreements and may copy licensed software only as permitted by the license. Unauthorized duplication of copyrighted software is a violation of federal copyright law. Employees should direct any questions about applicable software license agreements to their department supervisor or manager. Conflicts of Interest. A conflict of interest exists any time a employees loyalty to the Health Plan is or appears to be influenced by an outside interest. Employees are required to avoid financial or other outside relationships that might be adverse to the interests of the Health Plan, produce conflicting loyalties, interfere with effective job performance or involve even the appearance of such adverse interests, conflict or interference. Health Plan employees are prohibited from having a direct or indirect interest, financial or otherwise, in a corporation or business, engage in a professional activity, or incur an obligation of any nature that is in substantial conflict with or might reasonably tend to influence the discharge of the their official duties for the Health Plan. The Health Plans policy regarding conflicts of interest is straightforward: dont compete with the Health Plan and never let your dealings on behalf of the Health Plan be

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influenced or even appear to be influenced by personal interests, including those of your relatives, household members, significant others and domestic partners of employees (related parties). A good general rule is to assume that a potential conflict of interest exists any time an observer of a employees actions could question whether they are motivated solely by their responsibilities to the Health Plan. All employees are required to disclose any financial arrangement with a company or entity external to the Health Plan that might create a potential conflict of interest. Contacts with the Government and Outside Investigators. The Health Plan will cooperate in government investigations and with all reasonable demands made by any governmental entity. However, it is essential that the legal rights of the Health Plan and its employees be protected. If an employee of the Health Plan receives a subpoena, inquiry, or other legal document from any governmental agency regarding the Health Plans business, whether at home or in the workplace, the employee must immediately notify Corporate Counsel or the Compliance Officer of the Health Plan. The Health Plan does not prohibit a employee from speaking to any government investigator or agent. However, to best protect the employee and the Health Plan, if any governmental agency or representative of a governmental agency contacts a employee outside of the workplace concerning the Health Plans business, the employee may politely ask the agent to contact the Health Plans Corporate Counsel or Compliance Officer. Contacts with the Media. Only the Executive personnel of the Health Plan may act as the spokesperson for the Health Plan. If at any time a member of the media is requesting information, employees should immediately contact the Health Plans Compliance Officer. If any member of the media contacts an employee, kindly instruct them to contact the Compliance Officer Drug and Weapon-Free Workplace. The Health Plan is committed to being a drug-free environment. Any employee reporting to work under the influence of alcohol or an illegal or controlled substance shall be prohibited in the workplace and on any property under the control of the Health Plan and shall be subject to disciplinary action, up to and including termination. Any employee found to be involved in the unlawful manufacture, sale, distribution, dispensing, possession or use of a controlled substance shall also be subject to disciplinary action, up to and including termination. The use of alcoholic beverages is prohibited in the workplace or on Health Plan property. However, the CEO of the Health Plan may waive this prohibition with respect to any event sponsored by the Health Plan. Employees of the Health Plan are required to notify the Health Plan Compliance Officer within five (5) calendar days of a conviction for an offense involving a controlled substance. Equal Employment Opportunity. The Health Plan is committed to complying with all applicable civil rights, human rights and labor laws, to providing equal employment opportunity to all employees and job applicants, and to maintaining a workplace free from illegal discrimination, harassment, intimidation and retaliation. The Health Plan seeks to recruit, hire, train and promote applicants and employees without regard to age, color, disability, ethnicity, marital or family status, national origin, race, religion, sex, sexual orientation, veteran status or any other characteristic protected by applicable law. All hiring and promotion decisions are based on the qualifications of the individual applicants or employees. The Health Plan takes affirmative steps to ensure that applicants are hired, and employees are treated, in a non-discriminatory manner. The Health Plans commitment to equal opportunity principles applies to all aspects of employment, including recruitment, retention, promotion, compensation, benefits, and training. The Federal Fair Labor Standards Act (FLSA) requires that accurate time and leave Fair Labor Standards Act. records for all non-exempt employees of the Health Plan are maintained. The Health Plan compensates non-exempt employees for hours actually worked in one week over forty (40) hours. Employees must specifically obtain prior approval for overtime, compensatory, and equivalent time before it is worked. It is every Health Plan employees responsibility to prevent fraud, waste, and abuse. Fraud, Waste and Abuse. The Health Plan Fraud, Waste and Abuse Prevention Plan (contained in the Health Plan Compliance Plan) specifies individual responsibilities and actions regarding fraud and abuse. Fraud is defined as knowingly and willfully attempting to receive financial gain by making false statements or developing a scheme to receive anything of value. Abuse is defined as activities that result in excessive or unreasonable costs to the Health Plan, or other state or federal agencies.
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Employees of the Health Plan who are discovered in any type of fraud or abuse activity will receive disciplinary action, up to and including termination and possible prosecution, if applicable. Harassment - Sexual and Other. The Health Plan strives to provide a work environment free of sexual harassment or other harassment or discrimination based on age, color, race, national origin, veteran status, religion, sex, sexual orientation, ethnicity, marital or family status, disability or any other legally protected category. Even harassing conduct that does not rise to the level of unlawful harassment or is not prohibited by law in the particular jurisdiction of the employee may violate Health Plan policy and be grounds for discipline, up to and including termination. The Health Plan will not tolerate harassment in any form - conduct, speech, written notes, photos, cartoons or electronic mail. Employees of the Health Plan who observe or experience any form of harassment or discrimination should report the incident to the Health Plan Human Resources Director or Compliance Officer. Internal or Confidential Information and Intellectual Property. Private, proprietary and confidential information and intellectual property belonging to or in the care of the Health Plan is of great value to the company and to others. Confidential Information: Information that is categorized as internal or confidential must be used for Health Plan business only, and must not be discussed or disclosed to anyone outside of the Health Plan, including family members, without proper authorization. Nonpublic information about the Health Plan cannot be used for personal gain. Measures must be taken to protect all internal or confidential information and any other information that is not intended to be available to the public by keeping it secure, limiting access to those who have a need to know and avoiding discussion of internal or confidential information in public areas. internal or confidential information includes written documents, e-mails and technical data, along with the ideas, plans and processes that the Health Plan uses in its business every day. Information that comes to the Health Plan from a customer, supplier or competitor as part of its business should be treated as internal or confidential information, unless it is objectively clear that such information is not confidential to the customer, supplier or competitor. 14 Intellectual Property: TheHealth Plans trade secrets, sometimes called intellectual property, often result from a significant investment of the Health Plans resources. Intellectual property is an important asset that helps with our competitive advantage and must be protected. Intellectual property includes any invention, discovery, trade secret, technology, creation, scientific or technological development, computer software, or other form of expression of an idea that arises from the activities of employees of the Health Plan, or anyone using the Health Plans offices or facilities under the supervision of Health Plan personnel. Examples of intellectual property include the Health Plan name, logo, trademarks, copyrights, patents, software, ideas, inventions, discoveries, research plans and strategies. All employees must take measures to protect the Health Plans intellectual property and to avoid infringing on the intellectual property rights of others. Refer any misuse or infringement of the Health Plans intellectual property to the Health Plan Corporate Counsel. The Health Plan owns the intellectual property created by employees if the intellectual property is created by a employee within the scope of employment, created by the employee during work hours and/or with the use of the Health Plan facilities or supplies, commissioned by the Health Plan pursuant to a signed contract, fits within one of the nine categories of works considered works for hire under copyright law or results from research supported by federal funds or third party sponsorship. The Health Plan employee must disclose the intellectual property created by the employee to the Health Plan Compliance Officer well before he or she submits any information about the intellectual property for publication, or makes any public or private disclosure to a commercial entity. Kickbacks. Kickbacks are undisclosed payments, gifts, or services offered in return for something of value, increased business, or business referral. It is a criminal offense to receive or solicit any remuneration, including a gift, cash, bribe, rebate, or discount in return for referring an individual or potential member to the Health Plan or for any service offered by the Health Plan. It is also a crime to receive or solicit remuneration in return for purchasing, ordering, or arranging for or recommending purchasing, leasing, or ordering any good or service. Employees of the Health Plan who are involved in any type of kickback scheme will receive disciplinary action, up to and including termination and possible prosecution, if applicable.

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Outside Employment. The first responsibility of Health Plan employees is to the Health Plan. Outside professional commitments should not interfere with an employees responsibility to the Health Plan. There are numerous regulations governing outside employment. They cover paid employment and volunteer service, such as with a not-forprofit organization or other governmental entity. Generally, these regulations prohibit employees from outside employment that would cause a conflict of interest, reduce the ability to perform job duties as a Health Plan employee, or bring discredit to the Health Plan. If an employee is considering any form of outside employment or currently holds outside employment, the employee should contact their department supervisor or manager or the Human Resources Director to determine the regulations that apply to the particular situation. Full-time employees of the Health Plan must receive permission from the CEO of the Health Plan before accepting employment or independent contractor status of any type from any vendor who provides services to the Health Plan. The CEO of the Health Plan will determine whether this possible employment might create a conflict of interest situation at the Health Plan. Photocopying of Copyrighted Material. Most works should be presumed to be copyright protected, unless further information from the copyright holder or express notice reveals that the copyright holder intends the work to be in the public domain. Permission must be obtained from the copyright owner to copy copyrighted materials where copying extends beyond the boundaries of the guidelines contained in the copyrighted materials policy, advice of the Health Plans Corporate Counsel has not been sought, and, copying is not fair use. Political Activities. Employees may participate in the political affairs of their communities and country on an individual basis, on their own time and at their own expense. Employees may not make direct or indirect political contributions of any kind on behalf of the Health Plan, and will not be reimbursed for any such expenses. Further, employees of the Health Plan may participate in political activities provided such activities are not conducted during work hours, are not in contravention with the Constitution and laws of the United States and the State of Florida, does not interfere with the discharge and performance of the employees duties and responsibilities, and does not involve the use of equipment, supplies, or services of the Health Plan. In addition, employees of the Health Plan are not allowed to support or oppose (in writing or orally) any legislation purporting to be a Health Plan representative. Protected Health Information. The Health Plan is committed to conducting business in compliance with national standards for privacy, security, and electronic transactions of Protected Health Information as set forth in the Health Insurance Portability and Accountability Act (HIPAA). All employees of the Health Plan are expected to follow the Health Plans HIPAA policies and procedures. Confidential and proprietary information regarding the Health Plans members, including but not limited to medical and financial information, must be protected. Confidential information should not be disclosed to anyone outside of the Health Plan, including friends, family, business or social acquaintances, customers or suppliers. Employees of the Health Plan are not permitted to disclose confidential member information to any unauthorized person. An employees obligation not to disclose such information exists both during and after their employment with the Health Plan. The Health Plan is required to maintain an active and continuing records Retention and Disposal of Records. management program that identifies vital and confidential records and ensures the appropriate retention and disposition of records. No Health Plan employee should tamper with records, or remove or destroy them except in accordance with the approved retention and disposition policy. Harassment - Sexual and Other. The Health Plan strives to provide a work environment free of sexual harassment or other harassment or discrimination based on age, color, race, national origin, veteran status, religion, sex, sexual orientation, ethnicity, marital or family status, disability or any other legally protected category. Even harassing conduct that does not rise to the level of unlawful harassment or is not prohibited by law in the particular jurisdiction of the employee may violate Health Plan policy and be grounds for discipline, up to and including termination. The Health Plan will not tolerate harassment in any form - conduct, speech, written notes, photos, cartoons or electronic mail. Employees of the Health Plan who observe or experience any form of harassment or discrimination should report the incident to the Health Plan Human Resources Director or Compliance Officer.

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Workplace Health and Safety. All Health Plan employees should perform their duties in compliance with all applicable institutional policies, federal, state and local laws and standards relating to the environment and protection of worker health and safety. Employees should become familiar with and understand how these laws, standards, and policies apply to their specific job responsibilities. Each employee of the Health Plan is responsible for advising their department supervisor of any serious workplace injury or any situation presenting a danger of injury so that timely corrective action may be taken. Department supervisors of the Health Plan must report unsafe practices or conditions to the Health Plan Internal Risk Manager or Compliance Officer. The Health Plan strives to assure that all employees are provided a safe working Workplace Violence. environment. Violence in the workplace is not tolerated. To preserve workplace safety and security, an employee shall not possess weapons (regardless of whether they have a permit) of any sort including, but not limited to, firearms, ammunition, explosives, incendiary devices, knives, defensive incapacitating sprays and devices, and cases/holsters/sheaths for weapons on Health Plan property (subject to applicable law) in any company vehicles, or in the workplace or while acting in a business capacity. In addition, the Health Plan forbids acts or threats of physical violence, including intimidation, harassment, and/or coercion, that involve or affect the Health Plan (or its employees, vendors or members) or that occur on Health Plan property or in the conduct of Health Plan business off the company property. Employees who are involved in workplace violence against other individuals or verbal or written threats directed at individuals will be subject to disciplinary action, up to and including termination. Employees of the Health Plan who observe or experience any form of violence should report the incident to the Health Plan Human Resources Director or Compliance Officer

CODE OF ETHICS
1. No employee of the Health Plan shall accept or solicit any gift, favor, or service that might reasonably tend to influence their discharge of official duties or that he or she knows or should know is being offered with the intent to influence his or her official conduct. 2. No employee of the Health Plan shall intentionally or knowingly solicit, accept, or agree to accept any benefit for having exercised his or her official powers or performing his or her official duties in favor of another. 3. No employee of the Health Plan shall accept employment or engage in any business or professional activity that the he or she might reasonably expect would require or induce him or her to disclose confidential information acquired by reason of his or her official position. 4. No employee of the Health Plan shall disclose confidential information gained by reason of his or her official position or otherwise use such information for his or her personal gain or benefit. 5. No employee of the Health Plan shall disclose any protected health information of any member of the organization, unless such information is otherwise required by law or authorized. 6. No employee of the Health Plan shall transact any business in his or her official capacity with any business entity that is of like competing interest of the Health Plan, including entities in which he or she owns a substantial interest. 7. No employee of the Health Plan shall make personal investments that could reasonably be expected to create a substantial conflict between his or her private interest and the interests of the Health Plan. 8. No employee of the Health Plan shall accept other outside or dual employment or compensation that could reasonably be expected to impair his or her independence of judgment in the performance of his or her professional duties.

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