Ethics & Compliance Statement

Effective Date: July 20, 2021

As part of our commitment to providing quality care and service to our patients, Injured Workers Pharmacy LLC (“IWP”) is dedicated to establishing and maintaining an effective Ethics & Compliance Program. The purpose of our Ethics & Compliance Program is to promote an organizational culture at IWP that encourages good ethical conduct and compliance with all applicable laws and regulations; to assist all employees in the prevention, detection, and resolution of issues that relate to non-compliance with federal and state law; educate and train all IWP stakeholders; and foster the highest ethical standards as outlined in our Code of Ethics and Conduct (“Code”). It is IWP’s expectation that all of our employees, contractors, and business associates will comply with our Code and the policies established in support of our Code.

The following are the core elements of our Ethics & Compliance Program:

Oversight – Our Board of Directors oversees the processes by which we conduct business to ensure we operate in a manner that complies with laws and regulations and reflects our high standards of integrity. Additionally, our Chief Compliance Officer is responsible for developing, operating, and monitoring our Ethics & Compliance Program.

Written Standards – IWP’s Code is a statement of principles that supports our core values and guides our operations. Our Code, along with our compliance policies and procedures, provide written standards to help guide our employees in understanding the variety of legal, regulatory, and policy matters impacting our business operations.

Education and Training – We provide training and education to all employees on our policies, procedures, and applicable legal and regulatory requirements.

Communication – We actively promote open communication at all levels of the organization. Our employees are encouraged to speak up when they have questions or concerns about potential violations or unethical behavior and have a variety of avenues to do so, including via our EthicsPoint hotline.

Auditing and Monitoring – On an ongoing basis, we assess, evaluate, monitor, and audit compliance with our Ethics & Compliance Program.

Data Privacy and Security

IWP is also committed to protecting personal data. Our Privacy Policy defines our privacy standards and guides and underscores our commitment to the protection and security of personal and patient health information. To support this commitment, all IWP employees are required to complete IT security training.