Code of Conduct and Ethics

© 2020 Health System Solutions. All rights reserved.

1 Health System Solutions

Health System Solutions (“HSS”) is committed to a culture of honest and ethical behavior and to conducting our business with integrity. The way we conduct our business is as important as the services we provide. We will not compromise our values to achieve our business objectives. By embodying these values into our business, we are helping to ensure our continued success and reputation.

This Code of Conduct and Ethics (“Code”) provides guidance on critical policies and regulations that impact our business operations and where to go for help when the answer is not clear. We are all expected to abide by our Code and with the more detailed policies and procedures set forth in the HSS Employee Handbook and other corporate policies. This Code is not intended to cover every applicable law or address every ethical issue that an employee may confront. Ultimately, no Code of Conduct can replace good judgement and responsible behavior, including knowing when to seek guidance on the appropriate course of action.

It is important to know that this Code applies to all HSS employees in every part of the business, level or area.

If you are ever in doubt about the right course of action or observe an action inconsistent with our values or Code, raise the issue with your supervisor or to any of the many other resources available to you. Know that HSS will not tolerate retaliation against anyone for asking questions or raising concerns in good faith.

Thank you for your ongoing commitment to living our values every day.

Sincerely,

Marilia Garner Chief Executive Officer

Welcome to the HSS Code of Conduct and Ethics

Health System Solutions 2

Table of Contents

Build Trust and Creditability 3

Respect for the Individual 3

Create a Culture of Honest and Open Communication 3

Accountability & Reporting Concerns 3

Set tone at the top 4

Uphold the Law 5

Federal and State False Claims Act 5

Billing of Third-Parties 5

Competition 5

Proprietary Information 5

Avoid Conflicts of Interest 6

Gifts and Entertainment 6

Report Results Accurately 7

Accurate Public Disclosure 7

Corporate Recordkeeping 7

Promote Substance Over Form 8

Be Loyal 8

Confidential and Proprietary Information 8

Patient Information and Records 8

Use of Company Resources 8

Media Inquiries 9

Do the Right Thing 9

Record Retention 9

Relationship to HSS’s Employee Handbook and Training Programs 10

Acknowledgement 10

Enforcement & Sanctions 10

3 Health System Solutions

Build Trust and Creditability

The success of our business is dependent on the trust and confidence we earn from our employees, customers and owners. We gain credibility by adhering to our commitments, displaying honesty and integrity and reaching Company goals solely through honorable conduct.

When considering any action, it is wise to ask: will this build trust and credibility for HSS? Will it help create a working environment in which HSS can succeed over the long term? Is the commitment I am making one I can follow through with? The only way we will maximize trust and credibility is by answering “yes” to these questions and by working every day to build our trust and credibility.

Respect for the Individual

We all deserve to work in an environment where we are treated with dignity and respect. HSS is committed to creating such an environment as it brings out the full potential in each of us, which, in turn, contributes directly to our business success.

HSS is an equal opportunity employer and is committed to providing a workplace that is free of harassment and discrimination. Any employee who feels harassed or discriminated against should report the incident to his or her supervisor or to Human Resources.

Create a Culture of Honest and Open Communication

At HSS, everyone should feel comfortable raising concerns, particularly with respect to ethics or compliance concerns. Managers have a responsibility to create an open and supportive environment where employees feel comfortable raising concerns. We all benefit tremendously when employees exercise their power to prevent mistakes or wrongdoing by asking the right questions at the right times.

Accountability & Reporting Concerns

Each of us is responsible for knowing and adhering to the values and standards set forth in this Code and for raising questions if we are uncertain about HSS policy. If we are concerned whether the standards are being met or are aware of violations of the Code, we must report our concern through the established chain of command or to the Compliance Director or Compliance Hotline. HSS takes seriously the standards set forth in the Code, and violations are cause for corrective action up to and including termination of employment.

Suspected, potential, and known violations of this or any HSS Policy, or a suspected violation of any law, must be reported immediately. HSS will investigate the report and if improper behavior is found to have occurred, HSS will take appropriate action.

Employees are encouraged, in the first instance, to address such issues with their managers/supervisors or Human Resources, as most problems can be resolved swiftly.

If for any reason that is not possible or if an employee is not comfortable raising the issue with his or her manager/supervisor or Human Resources, HSS’s Compliance Director operates with an open-door policy. Any concerns raised to the Compliance Director will be treated confidentially and shared only on a need to know basis.

In addition, a confidential reporting mechanism is available via the Compliance Hotline. The Compliance Hotline is available 24/7 and offers the opportunity to report concerns anonymously. Reports can be made via phone by calling (888) 513-0053 or online: www.MyComplianceReport.com, Access ID - HSS.

Health System Solutions 4

HSS prohibits retaliation against any person who brings forth ethics or compliance concerns in good faith. Providing information known to be false or intentionally misleading is a serious matter that could result in discipline up to and including termination.

For more information, refer to the Non-Retaliation for Reporting Non-Compliance, FWA, and HIPAA Incidents Policy (COM-12) located on the HSS Policies page on HSS intranet site.

Set tone at the top

Management has the added responsibility to demonstrate, through their actions, the importance of this Code. In any business, ethical behavior does not simply happen; it is the product of clear and direct communication of behavioral expectations, modeled from the top and demonstrated by example.

To make our Code work, managers/supervisors are responsible for promptly addressing ethical questions or concerns raised by employees and for taking the appropriate steps to address such issues. Managers/supervisors should not consider employees’ ethics concerns as threats or challenges to their authority, but rather as another encouraged form of business communication. At HSS, we want the ethics dialogue to become a natural part of daily work.

5 Health System Solutions

Billing of Third-Parties

The intentional submission of any claim for payment from a third party, such as a Federal or State healthcare program or a private payer, that is false, fraudulent, inaccurate, incomplete or fictitious will not be tolerated. Any requests to deviate from accepted billing practices or any questions that may arise during the performance of your duties must be reported either through your established chain of command or to the Compliance Director or Compliance Hotline. Failure to report such information can lead to corrective action, up to and including termination

Competition

We are dedicated to ethical, fair and vigorous competition. We will sell HSS products and services based on their merit, superior quality, functionality and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities in connection with the purchase of goods or services for HSS or the sales of its products or services, nor will we engage or assist in unlawful boycotts of particular customers.

Proprietary Information

It is important that we respect the property rights of others. We will not acquire or seek to acquire by improper means a competitor’s trade secrets or other proprietary or confidential information. We will not engage in unauthorized use, copying, distribution or alteration of software or other intellectual property.

Uphold the Law

HSS’s commitment to integrity begins with complying with Federal and State laws, rules and regulations that govern the business activities of both HSS and the clients we serve in various locations. Further, each of us must have an understanding of the Company policies, laws, rules and regulations that apply to our specific roles. If employees are unsure of whether a contemplated action is permitted by law or HSS policy, they should seek the advice from their Manager or Compliance Department.

All employees are responsible for preventing violations of law and for speaking up if they see possible violations.

Federal and State False Claims Act

The Federal Government and many state governments have enacted criminal and civil laws pertaining to the submission of false or fraudulent claims for payment or approval to the federal and state governments and to private payers. The false claim laws, which include criminal, civil, and administrative penalties, provide governmental authorities with broad authority to investigate and prosecute potentially fraudulent activities, and include anti-retaliation provisions for individuals who make good faith reports of fraud, waste, and abuse.

HSS has established policies and procedures that reinforce our commitment to the highest ethical standards when it comes to submitting claims for payment on behalf of our clients to any payer. We require our employees and contractors to report any suspected improper conduct and we protect any person who reports such information from retaliation. HSS has an open-door policy and a Compliance Hotline, which offers the opportunity to make an anonymous report.

Health System Solutions 6

Avoid Conflicts of Interest

Conflicts of Interest We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. At times, we may be faced with situations where the business actions we take on behalf of HSS may conflict with our own personal or family interests. We owe a duty to HSS to advance its legitimate interests when the opportunity to do so arises. We must never use HSS property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with HSS.

Here are some other ways in which conflicts of interest could arise:

• Being employed (you or a close family member) by, or acting as a consultant to, a competitor or potential competitor, supplier or contractor, regardless of the nature of the employment, while you are employed with HSS.

• Hiring or supervising family members or closely related persons. • Serving as a board member for an outside commercial company or organization.• Owning or having a substantial interest in a competitor, supplier or contractor. • Having a personal interest, financial interest or potential gain in any HSS transaction. • Placing Company business with a firm owned or controlled by a HSS employee or his or her family. • Accepting gifts, discounts, favors or services from a customer/potential customer, competitor or

supplier, unless equally available to all HSS employees.

Determining whether a conflict of interest exists is not always easy. Employees with a conflict of interest question should seek advice from management. Before engaging in any activity, transaction or relationship that might give rise to a conflict of interest, employees must seek advisement from their managers/supervisors or Human Resources.

For more information, refer to the Conflict of Interest Policy (COM-20) located on the HSS Policies page on HSS intranet site.

Gifts and Entertainment

Our commitment to deliver excellence in a competitive business environment presents challenges that we must meet with integrity. In all our business conduct we must adhere to both the letter and spirit of all applicable laws, regulations and company policies.

The exchange of modest gifts or entertainment can establish trust and strengthen important relationships. However, we must distinguish between activities that help build business relationships, and activities that are—or appear to be— excessive, inappropriate, or intended to influence decisions that should be based solely on business considerations.

7 Health System Solutions

In addition, federal, state, local, and foreign laws generally prohibit us from providing and accepting gifts, entertainment, or other items of value, to or from a government official or employee. We must avoid creating an actual or perceived conflict of interest. We are strictly prohibited from offering anything of value in exchange for an official act by a government official or employee.

HSS has zero tolerance for bribery and any other forms of corruption.

Before offering or receiving anything of value to or from a government official or employee (or a relative of such government official or employee or other organization or individual because of their association with such government official or employee), HSS employees must obtain approval from the Human Resources.

For more information, refer to the Gifts and Entertainment Policy (COM-24) located on the HSS Policies page on HSS intranet site.

Report Results Accurately

Accurate Public Disclosure

We will make certain that all disclosures made in financial reports and public documents are thorough, fair, accurate, timely and understandable. This obligation applies to all employees, including all financial executives, with any responsibility for the preparation for such reports, including drafting, reviewing and signing or certifying the information contained therein. No business goal of any kind is ever an excuse for misrepresenting facts or falsifying records.

Employees should inform Executive Management and Human Resources if they learn that information in any filing or public communication was untrue or misleading at the time it was made or if subsequent information would affect a similar future filing or public communication.

Corporate Recordkeeping

We create, retain and dispose of our Company records as part of our normal course of business in compliance with all HSS policies and guidelines, as well as all regulatory and legal requirements.

All corporate records must be true, accurate and complete, and Company data must be promptly and accurately entered in our books in accordance with HSS’s and other applicable accounting principles.

We must not improperly influence, manipulate or mislead any unauthorized audit, nor interfere with any auditor engaged to perform an internal independent audit of HSS books, records, processes or internal controls.

Health System Solutions 8

Promote Substance Over Form

At HSS, we must have the courage to tackle the tough decisions and make difficult choices, secure in the knowledge that HSS is committed to doing the right thing. At times this will mean doing more than simply what the law requires. Merely because we can pursue a course of action does not mean we should do so.

Although HSS guiding principles cannot address every issue or provide answers to every dilemma, they can define the spirit in which we intend to do business and should guide us in our daily conduct.

Be Loyal

Confidential and Proprietary Information

Integral to HSS ’s business success is our protection of confidential company information, as well as nonpublic information entrusted to us by employees, customers and other business partners. Confidential and proprietary information includes such things as pricing and financial data, customer names/addresses or nonpublic information about other companies, including current or potential suppliers and vendors. We will not disclose confidential and nonpublic information without a valid business purpose and proper authorization.

Patient Information and Records

The services HSS offers its clients requires access to personal and health information about patients. The Health Insurance Portability and Accountability Act (HIPAA) protects the privacy of and limits the use of individually identifiable health information. In addition, state laws may establish additional restrictions. All employees, contractors, and agents must carefully avoid any unnecessary invasion of patients’ rights to privacy.

Improperly accessed patient information could also be used to illegally obtain goods, services or cash. Access should be limited to only what is necessary to perform your assigned duties, as permitted by law and allowed by HSS. Inappropriate access or release of information, whether intentional or not, must be immediately reported through your chain of command or to the Compliance Director or Compliance Hotline.

Use of Company Resources

Company resources, including time, material, equipment and information, are provided for Company business use. Employees and those who represent HSS are trusted to behave responsibly and use good judgment to conserve Company resources. Managers/supervisors are responsible for the resources assigned to their departments and are empowered to resolve issues concerning their proper use.

Generally, we will not use Company equipment, such as computers, copiers and fax machines, to conduct an outside business or support any religious, political or other outside daily activity, except for Company-requested support of nonprofit organizations. We will not solicit contributions nor distribute non-work-related materials during work hours.

9 Health System Solutions

In order to protect the interests of the HSS network and our fellow employees, HSS reserves the right to monitor or review all data and information contained on an employee’s company-issued computer or electronic device, the use of the Internet or HSS’s intranet. We will not tolerate the use of Company resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate.

Questions about the proper use of Company resources should be directed to your manager/supervisor.

Media Inquiries

HSS employees may be approached by reporters and other members of the media. In order to ensure that we speak with one voice and provide accurate information about the Company, you should direct all media inquiries to the HSS Chief Executive Officer and also include Guidehouse Corporate Communications. No one may issue a press release without first consulting with the HSS Chief Executive Officer. All Press Releases must be approved by the HSS Chief Executive Officer and Guidehouse General Counsel.

Do the Right Thing

Several key questions can help identify situations that may be unethical, inappropriate or illegal. Ask yourself:

• Is what I am doing compliant with the HSS guiding principles, policies, this Code and the client’s policies?

• Have I been asked to misrepresent information or deviate from normal procedure?

• Would I feel comfortable describing my decision at a staff meeting?

• How would it look if it made the headlines? • Am I being loyal to my family, my company and

myself? • Is this the right thing to do? • Do I need to access this confidential information

to do my job?• Do I need to access this patient record to

complete my task?

Record Retention

Employees and officers are expected to become familiar with the Company’s and clients’ policies regarding records retention applicable to them and to adhere to those policies. (In general, Directors are not responsible for retaining records relating to the Board of Directors’ activities; that is the corporate secretary’s responsibility.) If an employee, officer or Director becomes aware of a subpoena or a pending, imminent or contemplated litigation or government investigation relating to the Company, or has reason to believe that a violation of the Company’s or a client’s records retention policy has been or is being committed, he or she should contact the Company’s General Counsel immediately.

Relationship to HSS’s Employee Handbook and Training Programs

This Code does not supersede, alter or (except by necessary implication) incorporate by reference the more detailed policies and procedures set forth in the Company’s Employee Handbook. Although HSS does not expect to change this Code frequently, it may be necessary from time to time to revise the more detailed policies found in the Employee Handbook. HSS’s Employee Handbook and its employee training program are proprietary and confidential, and the Company hereby expressly denies waiving any right to assert claims that the contents of HSS’s Employee Handbook or its training are proprietary and/or confidential.

This Code and HSS’s Employee Handbook are not intended to, and do not in any way constitute, an employment contract or an assurance of continued employment. HSS does not create any contractual rights by issuing this Code or HSS’s Employee Handbook.

For more information, refer to the HSS Employee Handbook located on the HSS intranet site.

Acknowledgement

Employees, officers and Directors are accountable for knowing and abiding by these policies. At time of hire and annually thereafter, HSS will require that each employee, senior employee and officer sign an acknowledgment confirming that he or she has reviewed and understands this Code, has personally complied with it, and is unaware of any unreported violations involving himself, herself or others. A copy of this Code may be found on the HSS intranet (Team Portal) or on the HSS website www.healthsystemsolutions.com.

Enforcement & Sanctions

Enforcement of this Code is the responsibility of HSS senior management. Any violation of this Code may lead to corrective action, up to and including termination of employment. If you have questions, reach out to your leader and/or Human Resources.

Health System Solutions 10

© 2020 Health System Solutions. All rights reserved.2020-097d IP HSS Code of Conduct and Ethics