CODE OF CONDUCT AND ETHICS

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1 CODE OF CONDUCT AND ETHICS As revised on November 16, 2017, Approved by the Corporate Compliance Committee on November 17, 2017, and Approved by the Board of Directors on December 11, 2017

2 A MESSAGE FROM OUR CHIEF ETHICS AND COMPLIANCE OFFICER Dear Company Personnel: The standards of the (the Code ), which include your responsibility to promptly report suspected compliance violations and to cooperate with any follow-up investigations, serve as a guide for you to use as while performing your daily activities. Applicable to all parts of the DentaQuest organization, the Code serves as the embodiment of our commitment to maintain a culture of compliance and foster business and personal activities with the highest level of integrity. Our Code is a valuable resource to ethical decision-making, covering issues that may arise while performing our day-to-day responsibilities such as communicating with members and fellow Company Personnel. We all play an integral part in protecting our business and carrying out our Company s foundational principles. By having a fully comprehensive understanding of our Code, we are equipped to act ethically every day and maintain our Company s integrity. If you have any questions about the Code or wish to report suspected violations, you can contact me directly at or at You may also contact our Compliance Department at or anonymously and confidentially through our Compliance Alert Line at All reports are taken seriously and any retaliation for good faith reporting is prohibited. Courtney Ransom Chief Ethics and Compliance Officer

3 Mission To improve the Oral Health of all. OUR FOUNDATIONAL PRINCIPLES Mission, Vision and Values Vision Achieve optimum oral health by transforming the systems of care, finance, policy and community. Enterprise Objectives Be the leading voice in oral health Create disruptive innovation in the care and financing systems Be the largest dental benefits provider Values Our values define us. They give us perspective on what makes the Company a great place to build a career. Our daily decisions and actions demonstrate these values. Putting our values into practice creates long term benefits for customers, employees, dentists, shareholders, and the communities we serve. Everything we do comes back to our values. They are real. They are important. They are who we are. Collaborate and respect each other s diversity to achieve a common mission. Do the right things for the right reasons. Try new things, learn from our mistakes, and continuously improve. Stay positive, get involved, and collectively impact lives. Go beyond expectations. Have fun.

4 TABLE OF CONTENTS Introduction. 1 Taking Company Business Opportunities 1 Protection and Proper Use of Company Assets 1 Confidential Information 1 Compliance with the Law 2 Fair Dealing and Anti-Competitive Activities 3 Responsibility to Company Personnel 3 Accuracy and Retention of Business Records 4 Whistleblower Provisions 4 Document Retention 5 Compliance Reviews 5 Enforcement. 5 Conflict of Interest and How to Avoid It 6

5 I. Introduction The Code applies to Dental Service of Massachusetts, Inc., its subsidiary, DentaQuest, LLC, and their subsidiaries and affiliates (collectively, the Company ) and the Company s Board of Directors (the Board ), officers, employees and vendors (collectively referred to as Company Personnel ). The Company consists of Dental Service of Massachusetts, Inc. (DSM 1 ), all of DSM s subsidiaries and all entities which DSM is the ultimate parent including entities in which DSM or another DSM subsidiary is the sole member of an organization and Company Personnel is comprised of the Board 2, officers, employees and vendors. The Code is a starting point; it is not intended to be a comprehensive manual that covers every situation that Company Personnel might encounter. More specific requirements are contained in various corporate policies, procedures, and guidelines of the Company which have been and will be published from time to time. You can obtain these other policies, procedures, and guidelines from your supervisor or the Chief Ethics and Compliance Officer. This Code and all other Company policies are incorporated into and are part of the Compliance Program adopted and published by the Company. II. Taking Company Business Opportunities Company Personnel may not take for themselves opportunities that rightfully belong to the Company. These opportunities rightfully belong to the Company when, for example, the Company has pursued the opportunity, or when it has been offered to the Company, or when it is the kind of business the Company competes in, or when the Company has funded it, or when the Company has devoted facilities or personnel to develop it, or when it is in the same line of business as the Company s business. III. Protection and Proper Use of Company Assets Company Personnel have a responsibility to protect the Company s assets from loss, damage, misuse, waste, or theft. The Company s assets, such as funds, products, or computers, may only be used for business purposes and as otherwise pre-approved by management. The Company s assets may never be used for illegal purposes. The Company s property should not be taken out of Company facilities unless necessary and authorized in connection with Company work. IV. Confidential Information 1 At the time of the approval of this Code of Conduct, DSM is undergoing a corporate restructuring, through which Catalyst Institute, Inc. will become the ultimate parent company. As part of the corporate restructuring, the Board of Directors will adopt this Code of Conduct. 2 This Code applies to the Board of Directors, subject to any other actions taken or policies approved by the Board. Page 1 of 10

6 All confidential information or proprietary information of the Company must be protected and each of you has agreed to do so by signing a Confidentiality Agreement with the Company. Confidential or proprietary information includes, for example, pricing, inventions, technology developed for use by the Company, financial data, trade secrets and know-how, acquisition and divestiture opportunities, marketing and sales programs, research and development information, and customer and supplier information. Because of the nature of our business, confidential information also includes information that suppliers and customers have entrusted to us. Company Personnel should not disclose the Company s confidential or proprietary information to anyone within or outside of the Company unless the recipient generally needs this information to carry out his or her assigned Company responsibilities, or as an outsider who has been properly authorized by management to receive such information. Inquiries from the press, media, investors or the public regarding the Company should only be answered by the officers or employees designated to respond to such inquiries. The obligation not to disclose the Company s confidential or proprietary information continues after employment with the Company terminates. V. Compliance with the Law All Company business shall be conducted in accordance with all applicable federal and state laws, and in a manner that will reflect a high standard of ethics. The Company is engaged in a highly regulated business and as such, the laws and regulations applicable to the Company are far reaching and complex, and include laws, regulations and program directives governing insurance programs. Company Personnel must comply with all applicable laws, rules and regulations in each jurisdiction where the Company does business, and may not use a third party to perform any actions that are prohibited by law or against the Company policies. Violations of laws and regulations may subject an individual, as well as the Company to civil and/or criminal penalties. In order to comply with the law, Company Personnel must learn enough about the laws that affect the Company to spot potential issues and to obtain proper guidance on the correct way to proceed and to know when and where to seek advice. When there is any doubt as to the lawfulness of any activity, advice should be sought from the Company s Chief Ethics and Compliance Officer in consultation with a member of the Legal Department. Compliance with the law does not comprise our entire ethical responsibility; rather, it is a minimum, absolutely essential condition for performance of our duties. Perceived pressure from supervisors or demands due to business conditions are not excuses for violating the law. Any questions or concerns about the legality of an action should be addressed with the Chief Ethics and Compliance Officer or a member of the Legal Department. Company Personnel are required, and indeed have an obligation, to raise concerns promptly when they are uncertain as to the proper legal course of action or if they suspect that Page 2 of 10

7 some action may violate the law. The earlier a potential problem is detected and corrected; the better off the Company will be in protecting against harm to the Company s business and reputation. VI. Fair Dealing and Anti-Competitive Activities A. Fair Dealing No Company Personnel should ever use any illegal or unethical method to gather competitive information. Stealing proprietary information, possessing trade secret information that was obtained without consent, or inducing such disclosures by past or present employees of other companies is prohibited. B. Anti-Competitive Activities Company Personnel are required to comply with the antitrust and unfair competition laws of the United States. Certain agreements almost always violate competition laws. Never talk with or exchange information with competitors to: Fix prices this can include setting minimum or maximum prices, or stabilizing prices. Fix terms related to price, pricing formulas, trade promotions, credit terms, etc. Divide up markets, customers or territories. Rig a competitive bidding process, including arrangements to submit sham bids. Boycott a competitor or customer. Because of the risks, do not discuss competitive matters with competitors at any time or any place without authorization of legal counsel. Likewise, Company Personnel who are unsure if a contemplated action may violate fair competition laws should speak to the Legal Department first before engaging in such action. Examples of activities that may raise competition law issues and which should first be discussed with legal counsel include: Discussing joint ventures, mergers, acquisitions, marketing, purchasing or similar collaborative arrangements with competitors. Establishing exclusive dealing arrangements (e.g., contracts that require a company to buy only from or sell only to a DQ company). Tying or bundling together different products or services (e.g., contracts that require a buyer who wants one product to also buy a second tied product). Engaging in activities involving trade associations or setting industry standards. Serving as a director or officer in a company that competes with us. VII. Responsibility to Company Personnel The Company is committed to treating all Company Personnel with honesty, fairness and Page 3 of 10

8 respect, fostering diversity, and providing a safe and healthy work environment. Abusive, harassing or offensive conduct is unacceptable, whether verbal or physical. Examples include derogatory comments based on racial or ethnic characteristics and unwelcome sexual advances. Company Personnel are required to report harassment when it occurs. Furthermore, the Company is committed to providing all Company Personnel with a safe and secure environment. Accordingly, all Company Personnel will comply with all applicable health and safety laws and regulations as well as Company policies governing health and safety. All Company Personnel are responsible for immediately reporting accidents, injuries and unsafe equipment, practices, or conditions to a supervisor or other designated person. VIII. Accuracy and Retention of Business Records Accounting standards and applicable laws and regulations require that transactions and events relating to the Company s assets and operations be properly recorded in the books and accounts of the Company. To accomplish this result, all financial personnel shall make and retain books, records and accounts that, in reasonable detail, accurately, completely and objectively reflect transactions and events, and conform both to required accounting principles and to the Company s systems of internal controls. No false or artificial entries may be made. No entry may be made or recorded in the Company s books and records or reported in any disclosure document that misrepresents, hides, or disguises the true nature of the event or transaction, and all entries and reports must be made in a timely manner. In addition to financial records, the Company s general business records and communications should be clear, truthful and accurate. Specifically, all business records and communications related to Medicaid or Medicare members that are submitted on behalf of the Company to the United States Government (the Government ) should be clear, truthful and accurate to avoid committing a violation of the False Claims Act (the FCA ), applicable false statement prohibitions and any other applicable State and Federal anti-fraud law. Company Personnel shall not make, file, or use any false, fictitious, or fraudulent statements or documents in the course of business and are prohibited from falsifying, concealing, or covering up a material fact in the performance of their duties. All Company Personnel are responsible for immediately reporting any concern about the Company s business records or financial records, including any concerns about its accounting, internal accounting controls and auditing procedures to the Chief Ethics and Compliance Officer or a member of the Legal Department. IX. Whistleblower Provisions The FCA permits both the Government and private citizens or whistleblowers to bring civil actions for violations of the FCA s liability provisions. When a whistleblower brings such Page 4 of 10

9 an action, it is brought in the name or on behalf of the Government; the Government has an option to intervene at any time; and must approve any settlement. The FCA prohibits discrimination against any employee taking lawful actions under the FCA. The Company has specific policies regarding the FCA and employment protections for whistleblowers and other employees. Company Personnel should refer to these policies for guidance regarding such protections and potential financial awards through settlement. Company Personnel should consult a member of the Compliance Program or the Company s Legal Department for questions related to the FCA s whistleblower protections. X. Document Retention The Company has specific policies regarding retention and destruction of documents. Company Personnel should refer to these policies for guidance regarding the retention of documentation. Company Personnel should consult a member of the Company s Legal Department for questions related to the Company s document retention guidelines or the propriety of disposing of a Company document or record. XI. Compliance Reviews In accordance with our Compliance Program, the Company undertakes reviews of compliance with the Code and other policies and procedures from time to time. All Company Personnel are expected to cooperate in connection with such reviews. For details regarding such reviews, please review our Compliance Program guidelines or contact the Chief Ethics and Compliance Officer. XII. Enforcement The Audit Committee of the Board of Directors, having ultimate oversight responsibility of the Compliance Program, delegates oversight authority to the Corporate Compliance Committee, comprised of the Chief Ethics and Compliance Officer (as the chairman), General Counsel and members of senior management, with respect to the Compliance Program including this Code and ensuring that the Code and the Company s corporate policies will govern all business activities of the Company. Among other things, the Chief Ethics and Compliance Officer and the Corporate Compliance Committee are charged with monitoring compliance with the Code as provided in our Compliance Program and authorized to review and approve the Company s corporate policies that are reflected in the Code. A. Where to Go With a Question or Concern or to Report a Violation If you need an explanation of the Code or you want to know if a provision of the Code applies to a particular situation, the best place to start is with your supervisor or the Chief Ethics and Compliance Officer. Page 5 of 10

10 If you believe any Company Personnel is violating the Code or otherwise acting in an illegal or unethical manner, you must report it as required in our Compliance Program. Reporting is confidential and can be made anonymously by using the Company s Compliance Alert Line at (866) ; by contacting the Office of Inspector General s National Fraud Hotline at (800) ; or by reporting to the compliance department of our clients or upstream authorities. The Compliance Program will review all reported issues and concerns and will create an action plan to resolve the matter. Reporting a violation will not be considered an act of disloyalty, but an action which shows your sense of responsibility and fairness to the Company s customers, and fellow Company Personnel. You also help safeguard the reputation and the assets of the Company. Compliance with the Code is an integral part of every employee s job function, and is an element of all performance evaluations for management and supervisory level employees. Reporting violations of the Code is also necessary because in some cases failure to report an illegal act by another person is itself a criminal act for which you could be prosecuted. Violations of the Code may cause Company Personnel to be subject to appropriate disciplinary action, up to and including immediate termination. While all reports of violations and suspected violations are required, please note that it is unacceptable to file a report knowing it to be false or materially misleading. Retaliation against anyone reporting in good faith a known or suspected violation of the Code is prohibited. Anyone found to have retaliated against someone for making such a report will be subject to corrective action, up to and including termination of employment. Potential violations of the Code or other Company policies, concerns or complaints may be reported to your supervisor, the Chief Ethics and Compliance Officer, or a member of the Legal Department as provided in the Compliance Program. B. Dissemination of the Code The Company shall take appropriate steps to disseminate the Code to Company Personnel upon its adoption. Subsequent to its adoption, a copy of the Code will be made available to new Company Personnel joining the Company. Dissemination of any changes to the Code and all other policies of the Company is the responsibility of Company management and department heads. C. Waivers of the Code In certain extraordinary situations, a waiver of a provision of the Code (other than matters required by law) may be granted. Contact the Chief Ethics and Compliance Officer if you believe special circumstances warrant a waiver of any of the Code s provisions. Any waiver of the Code for executive officers or Board of Directors may be made only by the Company s Board of Directors. Page 6 of 10

11 XIII. Conflict of Interest and How to Avoid It A. General Guidance A conflict of interest occurs where an individual s private interest interferes or even appears to interfere with the interests of the Company as a whole. Conflicts of interest often occur when Company Personnel receive an improper personal benefit as a result of his or her position with the Company. Relationships with prospective or existing suppliers, contractors, customers, competitors or regulators must not affect your independent and sound judgment on behalf of the Company. Business decisions and actions must be based on the best interests of the Company and must not be motivated by personal considerations or relationships. In addition to the general need to prevent conflicts of interest, the Company is also subject to laws and regulations which govern contractual and other relationships. Such matters are discussed in more detail in specific Company policies. General guidelines to help you better understand several of the most common examples of situations that may cause a conflict of interest are listed below. However, Company Personnel are required to disclose to management and the Company s Chief Ethics and Compliance Officer or General Counsel, any situation that may be, or appear to be, a conflict of interest. When in doubt, it is best to disclose. B. Outside Employment Company Personnel may not work for or receive payments for services from any competitor, customer, distributor or supplier of the Company without prior approval of management. This prohibition extends to benefits, loans (including loan guarantees) and other forms of compensation. Any outside activity must be strictly separated from the Company employment and should not impact or harm job performance at the Company. C. Board Memberships Employees and officers who desire to serve on the board of directors or a similar body for an outside company or government agency must disclose the opportunity to the management of the Company for evaluation as to whether an actual or perceived conflict of interest exists. Helping the community by serving on boards of non-profit or community organizations is encouraged, and does not require prior disclosure. D. Family Members and Close Personal Relationships We believe in fair dealing with all our customers and vendors. For that reason, all entities that we conduct business with the Company should be fairly evaluated. Company Personnel may not direct Company business to an entity because a family member or close friend owns any part of or manages that entity. In addition, the activities of a family member or close friend in any entity that the Page 7 of 10

12 Company does business with may create a conflict of interest which can cause the loyalty of the Company Personnel to become, or appear to become, divided. Accordingly, all Company Personnel must disclose to the Chief Ethics and Compliance Officer or General Counsel any interest held by them in any entity doing business with the Company, including interests held by their immediate family, except for ownership of less than 2% of a public corporation. Company Personnel are also required to disclose any arrangements such as consulting or part-time employment arrangements or other dealings with such entity, or if any member of Company Personnel s family or any friend is employed or consults in a management capacity with such entity. It should be understood that this information shall not be regarded by its nature as undue or special influence. But this information needs to be disclosed to allow the Company to determine if any undue or special influence could appear to be involved in any sales to or purchases from the Company and in deciding what action the Company should take to safeguard its interests. E. Investments Company Personnel may not allow their personal investments to influence, or appear to influence, their independent judgment on behalf of the Company. Any Company Personnel who own any interest in any corporation or entity that directly or indirectly competes with the Company or any division or affiliate of the Company shall so advise the Chief Ethics and Compliance Officer or General Counsel. Any holdings of less than 1% in a public corporation whose stock is regularly traded on a stock exchange need not be reported; however, interests held in excess of that amount or in any private entity by Company Personnel or by members of the Company Personnel s immediate family must be so disclosed. Some investments are always wrong: Never invest in a supplier if you have any involvement in the selection or assessment of, or negotiations with, the supplier, or if you supervise anyone who has such responsibility; and Never invest in a customer if you are responsible for dealings with that customer or supervise anyone with such responsibility. Usually, however, whether an investment creates a conflict of interest is a matter of good judgment. When deciding whether an investment might create a conflict, ask yourself these questions: Would the investment affect any decisions I will make for my company? How would the investment seem to others inside my company, such as my co-workers would they think it might affect how I do my job for the company? How would it look to someone outside, such as a customer, supplier, stockholder or even the media? If there is any doubt about how an investment might be perceived, it should be disclosed Page 8 of 10

13 to the Chief Ethics and Compliance Officer or General Counsel. F. Gifts and Entertainment 1. Generally Gifts and Entertainment means anything of value, including discounts, loans, cash, favorable terms on any product or service, services, prizes, transportation, use of another company s vehicles or vacation facilities, stocks or other securities, participation in stock offerings, home improvement, tickets, and gift certificates. The potential list is endless these are just examples. 2. Gifts There are some gifts that can never be accepted by Company Personnel because they are just wrong in fact or by appearance. Company Personnel may not accept kickbacks, cash, lavish gifts or gratuities. Nor may Company Personnel accept anything that might make it appear that their judgment for the Company would be compromised. For example, Company Personnel may never: Accept any gift that would be illegal or result in any violation of law. Accept any gift of cash or cash equivalent (such as gift certificates, loans, stock, and stock options). Accept or request anything as a quid pro quo, or as part of an agreement to do anything in return for the gift. Accept any gift that you know would cause the person giving the gift to violate his or her own employer s standards. Company Personnel may accept items of nominal value, such as small promotional items bearing another company s name. In some situations, it would be impractical or harmful to refuse or return a gift. When this happens, discuss the situation with the Chief Ethics and Compliance Officer or General Counsel. Some business situations call for giving gifts. The Company s gifts must be legal, reasonable, properly recorded on the Company s books, and approved by management. Company Personnel may never pay bribes or provide any cash or cash equivalents to any person. Company Personnel may not provide any gift if it is prohibited by law, Company policy or the policy of the recipient s organization. For example, the employees of many governmental entities are prohibited from accepting gifts. If in doubt, check first. 3. Entertainment In general, the rules regarding gifts apply to entertainment as well. Use good judgment. Company Personnel may accept entertainment that is reasonable in the context of the business and that advances the Company s interests. For example, accompanying a business associate to a local cultural or sporting event, or to a business meal, would in most cases be acceptable. Page 9 of 10

14 Company Personnel must not participate in any entertainment that is unsavory, sexually oriented, or otherwise violates our commitment to mutual respect. Also, entertainment that is lavish, or frequent, or that lasts more than a day (including travel) may appear to influence one s independent judgment on behalf of the Company and therefore would be presumed inappropriate. Accepting entertainment that may appear inappropriate should be discussed with management in advance of accepting such entertainment. Company Personnel may provide entertainment that is reasonable in the context of the business. If you have a concern about whether providing entertainment is appropriate, discuss the issue with management in advance. G. Travel In general, Company Personnel may accept transportation and lodging provided by a Company supplier or other third party, if the trip is for business purposes and is approved in advance by the individual s supervisor. Unless prohibited by law or the policy of the recipient s organization, the Company may pay the transportation and lodging expenses incurred by customers, agents or suppliers in connection with a visit to a Company facility or product installation. The visit must be for a business purpose and must be approved in advance by management. Page 10 of 10

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