Conflict of Interest and Code of Ethics

A company's reputation for integrity is its most valuable asset and is directly tied to the conduct of its directors and employees. Employees must never use their position with the Company, or any access to the Company's patients, for personal gain, to advance personal interests, or to obtain favors or benefits for themselves, members of their family, or any other person, business, or entity.

The Company adheres to the highest legal and ethical standards applicable to our business. The Company conducts its work in strict observance of both the letter and the spirit of all applicable laws, and the integrity of every employee is essential. Clinical staff are also expected to follow the Ethics Code for Behavior Analysts published by the Behavior Analyst Certification Board (BACB).

Employees must conduct themselves in a manner that avoids actual or potential conflicts of interest. The following are examples of conflicts of interest that are prohibited in any aspect of an employee's job:

• Acting as a director, consultant, agent, or employee of a supplier, patient, competitor, or any other entity that does business with the Company.
• Owning a material interest in, being a creditor of, or holding another financial interest in a supplier, patient, competitor, or other entity that does business with the Company.
• Accepting from, or providing to, any supplier, patient, or competitor gifts, gratuities, special allowances, discounts, or other advantages not generally available to employees of the Company.
• Holding any significant direct or indirect personal interest in a business transaction involving the Company.
• Conducting outside activities that materially detract from, or interfere with, the full and timely performance of an employee's services for the Company.
• Influencing commercial transactions involving purchases, contracts, or leases in any way that would have a negative impact on the Company or its business.

Any employee who has, or is considering taking on, a financial interest or outside employment relationship that might involve a conflict of interest, or who is uncertain how this policy applies, must promptly discuss the situation with Human Resources and refrain from exercising responsibility on the Company's behalf in any matter that could reasonably be considered to be affected by the adverse interest.

Failure to disclose an actual or potential conflict may be grounds for disciplinary action. Nothing in this policy prohibits employee affiliations or activities protected by applicable federal or state law, including activity protected by Section 7 of the National Labor Relations Act, which preserves the right of employees to organize and to discuss with each other the terms and conditions of employment.

Employees of the Company must conduct their personal affairs in a way that does not jeopardize their duties and responsibilities to the Company and does not raise legal questions about their association with the Company. Employees who fail to do so may be subject to termination of employment.