Code of Conduct

Mission, Values, & Culture

The mission of ModernMD Urgent Care is to be the best urgent care provider by contributing to the health and well-being of our patients through:

• Serving underserved communities
• Friendly center teams
• Community integration
• Excellent customer services
• Leadership development of staff
• Delivering the best medical care

To realize that mission, ModernMD operates under the belief that:

If … Culture = Desired Behavior
And … Desired Behavior = Results
Then … Culture = Results

Therefore, to train to our desired behaviors, we promote the following values

Our Workplace

ModernMD is an Equal Opportunity Employer committed to providing a safe, respectful work environment that is productive and harassment-free.

To ensure that our workforce aligns with the diverse neighborhoods we serve, ModernMD practices equal opportunity hiring, and provides a work environment that welcomes employees of all backgrounds.

Harassment can take many forms, including but not limited to:

• Verbal or written racial, ethnic, religious, or
  sexual slurs, jokes or threats
• Ridiculing or displaying offensive materials related to a protected characteristic
• Making unwelcome sexual contact or advances, requests for sexual favors, or other verbal or physical conduct of a sexual nature

Harassment, discrimination, threats, and/or violent behavior will not be tolerated. If you feel that you have been subjected to harassment of any kind, please report the matter immediately.

ModernMD is a drug- and alcohol-free workplace.

The unlawful or unauthorized use, abuse, solicitation, theft, possession, transfer, purchase, sale, or distribution of controlled substances, drug paraphernalia, or alcohol by an individual in any of the following situations is strictly prohibited:

• While on ModernMD premises,
• While on ModernMD business (even if not on premises)
• While representing ModernMD

ModernMD is committed to providing a hazard-free work environment for all individuals and recognizes the need to comply with relevant federal, state, and local occupational health and safety laws (eg., OSHA).

Individuals must be equally committed to maintaining safe work practices and safe work environments, and should observe safety rules at all times.

Individuals who violate ModernMD safety rules will be subject to disciplinary action, up to and including termination.

Our Relationships

ModernMD aims to provide the best possible service to all of our patients in every neighborhood we serve.

To earn and maintain their trust in us as a healthcare provider, we are committed to protecting their privacy and security, and never participating in dishonesty, criminal conduct, or fraud.

As such, we must always:

• Verify written patient information
• Follow appropriate guidelines for disposing of written or electronic member information
• Take the utmost care not to mix up patient information
• Send all emails containing patient information in a secure environment
• Access or use patient information minimally, and only as needed to perform job duties
• Never share patient information with others who do not have a job-related need to know
• Never share login information to any system with others
• Log off or lock your devices when away from your workstations
• Report all privacy concerns or potential violations immediately to the Compliance Officer.

Our Business

Conflicts of Interest

Conflicts of interest arise when our personal, financial, social, or political interests interfere with our ability to make objective business decisions on behalf of ModernMD. Examples of conflicts of interest include, but are not limited to:

• Holding a financial interest in any business or entity that either does business with or competes against ModernMD
• Using company time or assets for personal or non-job-related use
• Gaining personal benefits from opportunities or resources presented to you by ModernMD
• Acquiring significant ownership interest in any business other than a privately held family business

You and the members of your household are expected to avoid real or perceived conflicts of interest with ModernMD.

External Commitments

Commitments outside of ModernMD also have the potential to create conflicts of interest. These includes:

• Working for another company
• Serving as a partner or board member of another company
• Running for public office / serving as a public official
• Running your own business
• Contributing to a charity, foundation, or nonprofit with conflicting interests from those of ModernMD

External commitments may be permitted if they are not likely to affect your ability to work at ModernMD and must be approved in advance by your manager.

Gifts & Entertainment

While there may be times that you may receive gifts from or give gifts to an external associate to demonstrate appreciation or friendship, please exercise judgment and discretion to avoid any impression that those gifts may influence any business decisions.

Fair Business Practices

ModernMD is committed to growing our business through superior service quality rather than through unfair or illegal business practices. From our patient encounters, to our marketing communications, to our relationships with our vendors and contractors, all aspects of our business are built on integrity and fair business dealings.

To avoid any appearance of unfair practices, you should not discuss ModernMD business with a competitor or supplier, nor should you disclose terms of any supplier relationships.

Assets & Information

• Assets & Property

ModernMD assets, including but not limited to information systems, intellectual property, funds, records, and physical property and facilities, can only be used for ModernMD business purposes.

Individuals are expected to exercise reasonable judgment when using said assets, and to protect and dispose of them according to company policy.

• Information

All company records and information relating to ModernMD or its patients must be kept confidential.

Unless you have a business reason to do so, company information may not be disclosed or removed from company premises without prior authorization.

Violation of the above policy could result in disciplinary action, up to and including termination.

• Funds

ModernMD funds must be handled with honesty and responsibility. Company funds, including corporate
credit cards, may only be used for authorized business purposes, and never for personal expenses.

Please be sure to follow all ModernMD guidelines relating to extraneous expenses and reimbursement requests.

• Secure Facilities

To protect the safety of our patients and colleagues, ModernMD facilities must be kept secure in the
following manners:

• • Have your employee badge with you at all times
  • Do not allow unauthorized individuals to access company facilities
  • If you see people without proper ID or unaccompanied in a restricted area, ask an authorized person to assist them to an appropriate area or contact security.

• Upholding ModernMD’s Reputation

• • Communication

Practice honesty & candor when communicating with patients, colleagues, and business stakeholders

• • Media Inquiries

Only authorized representatives may speak on behalf of ModernMD.

If you are contacted by the press or a member of the media, please direct them to MMD Support.

• • Electronic Activity & Social Media

When using social media or other personal communications, you should never give the impression of speaking on behalf of the company unless otherwise authorized.

• • Political Activities

When making political contributions or engaging in political activities on a personal basis, please take care to distinguish personal political views from those of ModernMD.

Using MMD assets in connection to any political activity is not allowed.

ModernMD also conducts regular credentialing screenings and comprehensive background checks on all employees to ensure everyone is in good standing.

• Financial Reporting & Record Keeping

Financial reporting and record keeping must be completed meticulously and accurately reflect the transpired transactions.

Improper or false accounting, documentation, or financial reporting is in direct violation of company policy, and may also be illegal!

Compliance Program Oversight

Interpreting the Code

Our Compliance Officer and senior leadership team interpret and apply the code.

If you have any questions or concerns, please direct them to the Compliance Officer or any member of the management or senior leadership teams.

Reporting to the Quality, Compliance & Safety (QCS) Committee

We report on the status of the Code compliance to the Quality, Compliance & Safety (QCS) Committee of our Board of Directors on a quarterly basis.

Any policies, procedures, and changes to improve or amend the Code are included in the quarterly updates.

Amendments to the Code

The current version of the Code is available for viewing on ModernMD’s All Company Yammer.

Significant amendments will be disclosed via email and Yammer. All amendments are reviewed by the Quality, Compliance & Safety Committee as well as our Board of Directors.