Code of Conduct. (Effective as of March 1, 2012)

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1 Code of Conduct (Effective as of March 1, 2012)

2 March 2012 To Board Members and all Employees: Everyone at Elements Behavioral Health, Inc. and its subsidiaries, including Promises Treatment Centers; The Ranch on the Piney River, Inc.; Sexual Recovery Institute, Inc.; TRS Behavioral Care, Inc. d/b/a The Right Step; EBH Southwest Services, Inc. d/b/a Journey Healing Centers; EBH Northeast Services, Inc. d/b/a Clarity Way; and EBH Acquisition Subsidiary, Inc. d/b/a The Recovery Place ( the Company ) should constantly strive to maintain the highest legal and ethical standards. This Code of Conduct was developed to ensure that we continue to uphold these shared values, and to provide the resources to help resolve any questions about appropriate conduct in the workplace. This Code of Conduct is being distributed to you every member and employee. You are expected to read it, and acknowledge in writing that you understand that it represents mandatory policies of the Company. In addition, if you have questions regarding this Code of Conduct, or encounter any situation that you believe violates the Code s provisions, or simply doesn t feel right, you should immediately consult your supervisor, another member of management or the Compliance Officer. You may also call the Corporate Compliance and Integrity Hotline at (800) Each one of us has an essential role to play in ensuring our organization s integrity. Each of us is responsible for conducting our business with the highest ethical standards, and for encouraging our coworkers to do the same. We ask you to assist us in supporting these principles which are so vital to achieving our mission. Thank you for continuing to make the Company an organization of which we can all be proud. Sincerely, David A. Sack, M.D. Chief Executive Officer Richard Whitney Chairman of the Board 3

3 Code of Conduct Care with Integrity We define ourselves by our values. o BE THE BEST. We will succeed by focusing on each person s abilities, performance, and character. We will measure the success of our efforts and improve upon them. o SERVICE. Helping others is central to what we do, and we will strive to be of service to our clients and our communities. o HOPE. We believe that each moment provides a unique opportunity for change and that success requires patience, persistence, and faith. o INNOVATION. We will apply the most advanced insights from psychology and medicine in order to transform the lives of our clients, their families, and the general public. o RESPECT. We will treat our clients and their families, our employees, and our partners in the community with respect and dignity. o The Compliance Program and Policies and Procedures describe how to make decisions that support these values. The Compliance Program and Policies and Procedures are a condition of employment for every employee. We do the right thing the first time, every time. o Doing the right thing is your responsibility and nobody has the authority to instruct you to deviate from the Compliance Program or policies and procedures. Contact the Compliance and Integrity Hotline if you feel that anyone has asked you to violate Company requirements. If you need help or are unclear about what to do, you have the responsibility to get help. You can talk with your manager, the Compliance Officer or call the Compliance and Integrity Hotline. We are committed to identifying issues to others and correcting them. o If we see a problem, we identify it to others and we fix it. Doing the right thing means standing by Company values even when it is not convenient. If you see something that is wrong, tell someone. We must all hold each other accountable for doing the right thing, and you have the full support of the Company when you do. 4

4 We are committed to meeting the state licensure program requirements. o The Company is licensed under various state laws and must comply with many requirements. The Company is fully committed to following the requirements of all state licensure programs and failure to do so will lead to disciplinary action up to and including termination. Care that Meets our Standards The Compliance Program applies to all of us to each employee, as well as the Board of Directors. Failure to follow or report a suspected violation of the Compliance Program or Company policies and procedures will result in disciplinary action up to an including termination. Within our first 30 days as a member of the Company Workforce and each year thereafter, you are required to certify that you have read and understood the Code of Conduct. Managers have a special responsibility. Supervisory and management personnel must endeavor to ensure that those who report to them have sufficient information to comply with law, regulation and policy, as well as the resources to resolve ethical dilemmas. They must help to create a culture within the Company that promotes the highest standards of leadership, ethics and compliance. This culture must encourage everyone in the organization to raise concerns when they arise. Ethical and compliant behavior must never be compromised in the pursuit of business objectives. We follow Company policies and procedures. For Company policies and procedures, contact the executive director s office or Compliance Officer, Brian Chao. Care with Honesty We are honest in what we write, say and do o Our clients depend on us to accurately document their treatment records. We make every effort to ensure that treatment records are clear and complete and reflect exactly the services that were provided to a patient. We are honest in our bills for services o We make every effort to submit accurate and truthful bills for our services, and will bill only for services that were actually provided, properly documented and coded. If we see a billing error, we involve a manager, the Compliance Officer or the Hotline. We investigate and correct the error prior to submitting the bill. If we have already billed, we correct the underlying problem and make appropriate refunds. If we are not sure how to correct the error, we report it to a manager, the Compliance Officer or the Hotline. We prohibit financial incentives to provide care When representing the Company in a marketing manner, we are accurate and truthful. 5

5 Care about Each Other We provide care with compassion o We treat all clients equally with compassion, dignity and respect. We never distinguish among clients based on race, ethnicity, religion, gender, sexual orientation, national origin, age, disability, veteran status or other characteristics protected by law. o We maintain appropriate supportive relationships with clients, and do not become personally, financially, socially or romantically involved with them. We protect the right to privacy and confidentiality o Our clients trust that we will protect the information provided to us including their health information and personal data. We access health and personal information and share it with coworkers only when authorized to do so and for the purpose of doing our jobs. We release information only with express written authorization from the client and in accordance with proper procedures. o Confidentiality shall be maintained and respected at all times. We are committed to diversity o We support equal opportunity employment. We embrace the diversity of our coworkers, vendors and clients. We never harass or discriminate on the basis of race, ethnicity, religion, gender, sexual orientation, national origin, age, disability, veteran status or any other characteristic protected by law. o We provide reasonable accommodations to employees who have physical or mental disabilities. We have a safe and drug-free workplace o We are committed to providing a safe, efficient and productive work environment for all employees and clients. We may not be under the influence of alcohol or drugs on Company property or during work time. Employees are required to report any unsafe situations to their supervisor. o If applicable, employees required to be certified to provide alcohol or drug addiction services must abide by and comply with all relevant requirements. We have a positive work environment o We do not tolerate conduct that disrupts our work environment including behavior that is disrespectful, hostile, violent, intimidating, threatening or harassing. Harassment can be particularly harmful in the work environment, thus we have a special responsibility to report any instances of it that we may see or know about. Requests for sexual favors, sexual advances or other unwelcome verbal or physical conduct of a sexual nature are violations of our values and policies. We never engage in sexual contact with clients. We speak up if a coworker s or client s conduct makes us feel uncomfortable. 6

6 Care about Limiting Gifts We do not let perks cloud our decisions o As employees, we may be offered gifts from an individual or organization who has a relationship with the Company. We may only accept perishable or consumable gifts given to a department or group. We may never accept cash or cash equivalents, such as gift certificates, and under no circumstances may you solicit a gift. o We do not accept any type of gift or entertainment that may give the appearance of bias in business decisions, transactions or service. Care about Conflicts We avoid conflicts of interest. In our work, we have a duty to put the interests of the Company before our own. We avoid conflicts of interest where someone might question whether we are acting for the Company s benefit or for personal gain. We report any potential, perceived or actual conflict to our supervisors as soon as possible. Reporting Obligations We report any activity that potentially violates the Compliance Program or Company policies and procedures. The Compliance and Integrity Hotline works as follows: o If you contact the Compliance and Integrity Hotline, your call will be answered 24 hours a day, seven days a week. o When reporting it is important for you to have as many facts as possible to report the information to the appropriate individuals for investigation and resolution. Callers may call back and check on the status of the investigation. To protect your confidentiality and privacy, we do not disclose the details of the investigation or any disciplinary action. However, the Hotline will inform you whether the investigation is complete and if the issues were addressed. o The Hotline is independent and anonymous. The Hotline does not have access to caller ID and thus you can make your call anonymously if you wish. When you call, we need enough details to investigate your concerns including facility, department and, in some limited circumstances, your name. If the caller discloses his or her name but, requests confidentiality, your identity will remain confidential to the extent permitted by law. o All reports of an ethical violation must be made in good faith. Do not make an ethics report if you do not believe in good faith that the Compliance Program or Company policies and procedures have been violated. Appropriate disciplinary action will be taken if information has not been provided in good faith. We do not tolerate retaliation. o When an employee reports a problem or concern in good faith, calls the Hotline or cooperates with an investigation or corrective action, the employee is protected from retaliation, retribution or harassment. The Company takes reports of retaliation very seriously. If you feel that you have experienced retaliation, immediately report it to the appropriate manager who is not involved in the issue or contact the Hotline. Any time there is an allegation of retaliation, the allegation will be investigated and appropriate steps will be taken to protect those who report retaliation. 7

7 Compliance Support The Company s Compliance Officer is Brian Chao. o Mailing Address: 5000 E. Spring Street, Long Beach, CA o Phone Number: (562) , Extension 6518 The Company s Compliance and Integrity Hotline is available 24 hours a day, 365 days a year. Callers to the Hotline may remain anonymous and those who choose to give their names will have their identity protected to the extent allowed by law. The anonymous Hotline can be reached at (800)

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