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Code of Conduct and Business Ethics

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Code of Conduct and Business Ethics

Introduction

Doctor On Demand, Inc. (“Doctor On Demand”) has adopted this Code of Conduct & Business Ethics (“Code”) regarding interactions with patients, healthcare professionals (“HCP”) and our business conduct within the industry generally. All interactions between Doctor On Demand and patients and HCPs must be carried out in a responsible, ethical, professional and legal manner. This Code describes the fundamental principles and standards to which all individuals must adhere, including board members, officers, employees, contractors, and agents (referred to in this Code of Conduct as “Company Representatives”). This Code sets a minimum standard. Laws and industry guidance that set higher standards, or more specific conditions, take precedence over this Code.

Doctor On Demand will ensure that all Company Representatives are appropriately trained on the requirements of this Code. Doctor On Demand also will develop, implement and maintain a Corporate Compliance Program and other written Compliance Program Policies and Procedures that are consistent with this Code. Any conduct that violates this Code is prohibited. Compliance with this Code and related policies is mandatory. Violations can have serious consequences for Doctor On Demand and for Company Representatives. This Code incorporates principles set out in

  • Conduct his/her responsibilities in compliance with this Code;
  • Comply with Doctor On Demand’s Corporate Compliance Program and any written policies, procedures and other guidelines;
  • Protect Doctor On Demand’s reputation by actively supporting ethical behavior;
  • Promptly report any potential or actual non-compliance; and
  • Fully and honestly cooperate in any investigation of alleged violation of this Code or Doctor On Demand’s Compliance Program Policies and Procedures.

Doctor On Demand’s Corporate Compliance Program

Doctor On Demand is committed to conducting its business in compliance with the Federal and state laws, regulations and other requirements that govern our operations. Doctor On Demand provides resources to assist every individual within the Company, as well as our agents and vendors, to act in a legal and ethical manner.

Reporting Potential Violations

To encourage a workplace culture that keeps each Corporate Representative accountable to each other, Doctor On Demand provides several methods for individuals to make reports in an anonymous manner. These include a Compliance Hotline and other forms of confidential communication. Our policy is to ensure the all good faith reports of misconduct or noncompliance are immediately investigated. Doctor On Demand has a strict non-retaliation policy to protect Doctor On Demand Representatives who raise concerns in good faith. No action of reprisal or retaliation will be taken against any Doctor On Demand Representative for reporting a compliance concern or asking a question regarding our Compliance Program. Calls to the hotline or other types of reporting do not protect individuals from appropriate disciplinary action regarding their own performance or conduct.

Training and Education

The proper education and training of Company Representatives is a significant element of an effective compliance program. Doctor On Demand is committed to the education of its Company Representatives on issues related to corporate compliance. As such, Doctor On Demand has developed a training program that consists of compliance training to new hires and general training to all Company Representatives, and specific training sessions designed to target particular issues that only impact certain Company Representatives at Doctor On Demand. Attention to training and compliance will be an integral part of the Company Representative evaluation process. Failure to comply with training and compliance requirements will result in disciplinary action, including possible termination.

Healthcare laws and regulatory requirements

Doctor On Demand is committed to full compliance with all Federal and state laws and regulations applicable to our business, including but not limited to, the Federal Food, Drug and Cosmetic Act; Anti-Kickback Statutes; and patient privacy and confidentiality.

Fraudulent Conduct is Prohibited

Doctor On Demand does not tolerate fraud and is committed to the rigorous investigation of any suspected cases of fraud. Should any Doctor On Demand Representative believe they have good reason to suspect a colleague or other individual is engaged in fraud or an offense involving Doctor On Demand or a serious infringement of the Code, he or she should report such unethical action his or her or supervisor to the CCO.

Privacy Requirements

Doctor On Demand respects the confidential nature of patient health information. Therefore, Doctor On Demand must comply with all Federal and state health information privacy and security laws. Generally, unless otherwise permitted or required by law, Doctor On Demand will not disclose patient health information without prior authorization. Doctor On Demand and its business partners will limit the collection of, and access to, personal data to circumstances that are consistent with clinical quality and other specific, legitimate business needs and applicable laws and regulations. All personal data must be treated as confidential unless otherwise required, secured against unauthorized access, and retained only for as long as it is necessary. Doctor On Demand has adopted a number of additional Compliance Program Policies and Procedures addressing privacy issues that may affect its business activities.

Sanctioned/Excluded Individuals and Entities

The Federal government and many state agencies pay for Doctor On Demand’s products. Individuals and/or entities may be excluded, debarred or suspended from participating in Federal or state programs for various reasons, including inappropriate use of Federal or state funds. Doctor On Demand will not knowingly employ or contract with any individual or business which is excluded, debarred or suspended from participating in any government program. Generally:

  • Promotional material and communications must be accurate, balanced and not misleading in any respect. Claims must be compliant with medical, legal and regulatory standards.
  • All promotional material must be reviewed and approved by Doctor On Demand before use.
  • All promotional and advertising activities targeted toward patients will be in compliance with laws, regulations and Doctor On Demand Policies and Procedures.

Interactions with Healthcare professionals

Relationships with HCPs are heavily regulated and strictly enforced. An HCP is any individual or entity directly or indirectly involved in the delivery of health care services or items to patients and that can purchase, lease, prescribe, recommend, use or arrange for the purchase, lease or use of Doctor On Demand’s products or services. Doctor On Demand’s interactions with healthcare professionals, organizations and other authorities must be made in compliance with applicable laws, regulations, and Doctor On Demand Compliance Policies and Procedures. Our general policy can be expressed in two main points:

  • Doctor On Demand or its Representatives may not condition a financial arrangement or provide free services or grants to HCPs in exchange for any agreement to purchase, order or recommend Doctor On Demand products, or as a reward for high volume.
  • Payments to HCPs will only be provided to HCPs in exchange for the provision of services for which there is a legitimate business need and a written agreement that provides for fair market value compensation.