Liberty's Corporate Compliance

Liberty and its affiliated companies are committed to full compliance with all applicable laws and regulations, policies and procedures, and contracts. Compliance at Liberty is a two-pronged approach: one prong is general, high-level compliance, and the other prong is specific operational program-department compliance. The general, high level compliance is administered and overseen by the Chief Compliance Officer. The specific operational program-department compliance is generally the responsibility of each operational and business unit leader. The Chief Compliance Officer will work in conjunction with all operational and business unit leaders to ensure that Liberty and its employees, contractors, vendors and client remain compliant with Liberty’s compliance obligations.

In order to attain its compliance-related goals, all Liberty employees and contractors should report and actual or perceived violations of any law or regulation, policy or contract. All potential issues or violations that are reported, and that are deemed to be compliance matters, will be investigated in a timely manner by the Chief Compliance Officer. Upon investigation, findings will be obtained and recommendations, up to and including disciplinary and corrective action, will be made. Everyone should feel that they can freely communicate their concerns to their immediate supervisor or to the Chief Compliance Officer. Liberty will treat any such report confidentially to the maximum extent that it can consistent with the fair and rigorous enforcement of the Liberty Compliance Program and the requirements of the law.

It is Liberty’s express policy that no adverse action or retribution, of any kind whatsoever, will be taken by Liberty against any person due solely to the reporting of a suspected issue, violation or irregularity.

Liberty recognizes that effective and timely communication is the foundation of an effective Corporate Compliance Program. The Chief Compliance Officer ensures that there be several methods of reporting compliance concerns or incidents, some which allow the reporter to remain anonymous if they wish. If you are aware of a potential compliance issue, please report it immediately and provide sufficient information in order that it can be investigated. Incidents or concerns can be reported via several methods:

Report to your supervisor
Report directly to John Beck — the Chief Compliance Officer via:

mail: 401 E. City Ave. Suite 820, Bala Cynwyd, PA 19004

email: john.beck@libertyhealth.com or corporatecompliance@libertyhealth.com

phone: (610) 668-8800 ext. 405

Call the Liberty Employee Help Line at: (800) 653-7174 (which can be done anonymously if the caller desires)
Via the Corporate Compliance Incidents/Issues Form and email to the Chief Compliance Officer to either of the above email addresses

To reiterate, no person shall be disciplined or suffer any adverse employment, other action or other retaliation solely for making a compliance report or complaint in good faith.

The Liberty Compliance Program exists in part so that Liberty may obtain timely advice of legal counsel regarding compliance related issues. The Chief Compliance Officer also acts as legal counsel to Liberty. All communications to or from the Compliance Officer or the Liberty Legal Department in connection with a known or suspected compliance matter or report may be protected by the Attorney-Client Privilege, which belongs to Liberty. Liberty’s attorneys employed or retained by Liberty do not represent the personal interests of any Liberty employee or contractor. Additionally, there is no attorney-client privilege between the Compliance Officer or any other attorney and person reporting a compliance incident, or a person interviewed during a compliance investigation.

Liberty strives to cultivate a compliant work environment. Accordingly, directors, managers, and supervisors are integral part of the success of the Compliance Program. They bear primary responsibility that their programs and departments operate in compliance with all applicable requirements. Managers and supervisors must be sensitive to compliance concerns. While they will not ordinarily be involved in compliance investigations, sometimes they may be asked to assist the Chief Compliance Officer in an investigation. Management should not conduct or be involved in any investigation without the request or authorization of the Chief Compliance Officer. If any manager receives a compliance related complaint or inquiry, it should be forwarded immediately to the Chief Compliance Officer. Any questions related to any aspect of compliance should be directed to the Chief Compliance Officer.