Business Practices

🚨 Conflicts of Interest

We all have a duty to avoid situations that create a conflict of interest. A conflict of interest can occur when you or a family member have a personal interest, activity, or relationship that could interfere or appear to interfere with your ability to make objective business decisions in the best interest of besa Health. Conflicts are not always obvious or easy to identify. As examples, conflicts of interest may arise when you (or a family member):

• Engage in activities that compete with besa Health business interests, or appear to do so

• Work for or provide other service (such as consulting or acting as a paid advisor) to a current besa Health supplier, customer, landlord, or competitor or one who seeks to do business with besa Health

• Act on behalf of anyone besides besa Health in a transaction with besa Health (for example, helping someone sell products and/or services to besa Health)

• Have an ownership or financial interest in a besa Health supplier, customer, landlord, or competitor

• Use company proprietary or confidential information for personal gain or to benefit a non-besa Health business venture

• Supervise, have a direct/indirect reporting relationship, or make employment decisions about a family member or close friend who is also employed at besa Health

• Receiving or giving any gift or favor that is not permitted under the Global Gifts and Entertainment Standard If you have or become aware of a real or potential conflict of interest, you must promptly disclose it.

You should disclose the situation to your manager, Partner Resources, or Ethics & Compliance. Many conflicts can be avoided or properly managed when they are promptly disclosed.

🎁 Gifts and Entertainment

besa Health is committed to maintaining the highest ethical standards in all business transactions.

besa Health defines a business courtesy as an item offered or provided for which the recipient does not pay the full value. Business courtesies can come in many forms, including but not limited to gifts, entertainment, meals, hospitality, travel, discounts, and other favors.

Giving or receiving business courtesies can often be customary and a way to express gratitude or build goodwill in business relationships. However, giving or receiving business courtesies with customers, suppliers, or other third-parties with whom besa Health does or may do business requires careful consideration and should never be given or accepted if it might influence our professional relationships or business decisions, create a sense of obligation, or give the appearance of doing so.

You should always be aware of how accepting or offering a business courtesy might be perceived by the public, by other entities we do business with, and by other besa Health partners.

You must follow the limits and requirements of applicable company policy, which in some situations may require obtaining written prior approval.

Trading items of value with other businesses, including shops and restaurants, is strictly prohibited.

Any gift or business courtesy given must be accurately recorded in detail in our company financial records.

If you are not certain whether any gift or other business courtesy is appropriate, you must consult with your manager, Partner Resources, or Ethics & Compliance before taking any action.

Gifts to Government Officials: There are strict and complex laws when conducting business with government officials. Giving or offering even nominal gifts (such as promotional items or a meal) to a government official may violate the law. Anything of value offered or given to a federal, state, or local government official or employee must be pre-approved and comply with the company’s Global Anti-Bribery Standard.

Immediately report allegations of bribery or attempted bribery directly to Ethics & Compliance.

📕 Bribery and Corruption

besa Health competes fairly, honestly, and with integrity everywhere we do business. We never attempt to gain an unfair business advantage through bribery, kickbacks, or corruption in any form. We comply with the U.S. Foreign Corrupt Practices Act (FCPA), UK Bribery Act (UKBA), and the anti-corruption laws, rules and regulations where we operate, requiring the same of our business partners, staff members, contractors, and third parties.

besa Health members are prohibited from offering, promising, giving or accepting cash and cash equivalent or anything of value to improperly influence the outcome of any business decision. Nor do we allow our agents, intermediaries or other third parties to do so on our behalf. Bribes are not limited to cash. A bribe can be gifts, travel, meals, entertainment, hospitality, offers of employment, and charitable or political contributions.

We take particular care when working with or evaluating prospective third parties for bribery and corruption risks. We recognize the heightened risks of corruption when dealing with public officials and take appropriate steps to address them. Partners should never offer facilitation payments or favors when negotiating with governments, or public officials.

🎙️ Sales Practices and Advertising

besa Health competes on the merits of our products and services in all sales and advertising. Our communications with our patients or potential patients must be truthful and accurate. When we say something about our products and services, we must be able to substantiate it. We sell the quality of what we do; we do not disparage our competitors.

✖️ Fraudulent Activity

besa Health is committed to the highest ethical standards in all business transactions, relationships and partnerships and therefore prohibits all types of fraud, including asset misappropriation (theft), corruption and financial and non-financial misrepresentation. besa Health teams are expected to assess and implement anti-fraud processes and controls, safeguard our assets, be honest and trustworthy in their business dealings and disclosures, comply with applicable laws and regulations and report any known or suspected internal or external misconduct.

Fraudulent activity may take many forms, including:

• Theft of assets by internal or external schemes, such as cash theft, payments to fictitious vendors or partners, account take-overs and improper issuance.

• Improper revenue recognition, intentional overstatements of assets and understatement of liabilities

• Falsification of quality assurance reports, manipulation of environmental health and safety records or falsification of patient records and metrics.

Should you have any questions or oppose besa Health's business practices, please contact your hiring manager immediately.