NO BUSINESS WITH EXCLUDED INDIVIDUALS OR ENTITIES

We expect all individuals and entities associated with WIN to be appropriately credentialed, licensed and otherwise qualified to perform their duties. WIN does not do business with, employ, or bill for services rendered by individuals or entities that are excluded or ineligible to participate in federal healthcare programs. WIN personnel and vendors have a responsibility to report to their supervisor, Human Resources, the Compliance Office (as applicable) if they are excluded, debarred, or otherwise ineligible to participate in healthcare programs.

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COOPERATE WITH INQUIRIES, AUDITS, AND INVESTIGATIONS

We cooperate with government inquiries as well as internal and external audits and investigations. When receiving non-routine requests, we consult with the Legal Department or Compliance Office to ensure that requests are handled properly. We are truthful in what we say. We never alter or destroy records in violation of the law or WIN.

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USE RESOURCES RESPONSIBLY

We use WIN resources responsibly for WIN business purposes, not for personal gain. We spend WIN funds wisely, eliminate waste, and control operational costs without compromising patient care. We use physical assets like computers and technology for WIN business, and we protect those assets from loss, damage, and theft. We don’t waste supplies, equipment, space, or time. We protect intellectual property and respect patents, software licensing, copyright, and other IP agreements.

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CONDUCT POLITICAL ACTIVITY AND FUNDRAISING APPROPRIATELY

WIN respects its workforce members’ rights to participate in or refrain from political and fundraising activities on personal time. Workforce members must follow applicable policies relating to use of WIN resources for political activity, engagement in political activity while on work time, and similar issues. Workforce members may not inappropriately force, direct or encourage coworkers to support or contribute to a political cause, candidate, or party in violation of the law or applicable policies.

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DISCLOSE AND APPROPRIATELY MANAGE CONFLICTS OF INTEREST

We disclose and appropriately manage conflicts of interest. Workforce members must report any actual or potential conflict of interest. Conflicts of interest are situations in which personal considerations may affect, or have the appearance of affecting, our loyalty and ability to fulfill our responsibilities to WIN. Depending on the circumstances, a “conflict of interest” might include: activities outside of WIN with a competitor or in violation of our policies, supervising a close relative, purchasing stocks based on confidential information, accepting gifts from a vendor, patient, or fellow provider, or causing WIN to contract with vendors with whom you have a personal or financial interest. If you have questions about what might be a conflict of interest, review WIN policies and speak with your supervisor or the Compliance Office.

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PROHIBIT BRIBES, KICKBACKS, OR PAYMENT FOR REFERRALS

We do not offer or accept bribes or kickbacks. Bribes and kickbacks are money, gifts, or special treatment given to someone in exchange for a favor. The favor may be many things, from a promise to make patient referrals to a promise to use a particular vendor’s product. We also do not offer or accept “something of value” for patient referrals or services. “Something of value” includes money, services, gifts, entertainment, or anything else of value to the recipient. As this is a highly complex area of the law, workforce members must take special care and promptly refer any questions to the Compliance Office.

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PROHIBIT CERTAIN INDUCEMENTS AFFECTING PATIENT CHOICE

The law prohibits WIN and its workforce from offering certain inducements that may affect a patient’s decision about where to seek care. For instance, it may be illegal to offer copayment waivers, free services, gifts, and other inducements to encourage patients to receive care at WIN. As this is a highly complex area of the law, work force members must take special care and promptly refer any questions to the Compliance Office.

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REPORT COMPLIANCE CONCERNS WITHOUT FEAR OF RETALIATION

Work force members are encouraged to contact the Compliance Office whenever they need clarification or direction regarding Compliance issues (including this Code of Conduct). Work force members are required to report suspected violations of the Code of Conduct, policies, procedures, the law, and regulations to a supervisor, the Compliance Office, or the confidential Compliance Hotline. Retaliation is not permitted against anyone who seeks advice, raises a concern, or reports misconduct in good faith. Such retaliation should be reported immediately to the Compliance Office.

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RECORD AND REPORT INFORMATION ACCURATELY

We keep accurate records about our patients, our workforce, clinical activities, and financial transactions. It is the responsibility of each of us, when engaged in recordkeeping on behalf of WIN (including workforce timecards, medical records, and patient bills), to be accurate and honest. For example:

• We do not sign another person’s name to documents or share each other’s passwords.

• We amend the medical record only in accordance with WIN policy and applicable law.

• We do not fabricate, falsify or plagiarize when proposing, conducting or any activities.

• Our financial records conform to applicable accounting principles.

• We retain documents for the length of time described in our document retention policies.

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DOCUMENT, CODE, BILL AND COLLECT APPROPRIATELY

We handle claims for payment of services with integrity to avoid fraud, waste and abuse in healthcare. All WIN workforce members are expected to comply with federal healthcare program requirements, including, but not limited to, Medicare / Medicaid rules and federal and state False Claims Acts. We bill only for medically necessary services rendered by eligible providers and properly documented and coded. We respond to patient and payer questions concerning charges in an accurate and timely manner. We correct any billing errors of which we have knowledge and refund payments received in error to third party payers and patients, with appropriate documentation. If you become aware of inaccuracies, notify your supervisor so that the error can be corrected. If you see problems with claims that are not being corrected, contact the Compliance Office or Compliance Hotline. We do not do business with excluded individuals or entities.