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Dear Colleagues,

We are committed to achieving our mission to help every patient who would benefit from our knowledge in full compliance with our values, all applicable laws, government regulations, third party payor requirements and our own policies. The Healogics Compliance Program demonstrates a commitment to our corporate values by:
(1) defining and guiding the conduct expected of all who are associated with Healogics;
(2) providing guidance to help resolve questions related to business conduct and other ethical issues; and
(3) establishing a mechanism to report possible violations of standards and laws. Those standards and laws include federal and state regulations governing healthcare programs, fraud and abuse matters, ethics, privacy and security requirements, corporate governance and other aspects of our operations.
Our Compliance Program applies to our relationships with employees, providers, vendors, regulatory agencies, competitors, consultants, and the general public. Since laws related to healthcare are complex, a strong compliance program is crucial to our company’s reputation and success. Having a strong compliance program helps Healogics maintain its commitment to being an honest and responsible corporation by identifying and preventing illegal and unethical conduct; by improving the quality and consistency of patient care and services; by creating a structure for reporting potential problems; and by developing procedures for prompt and thorough investigation of suspected misconduct.

A key element of the Compliance Program is our Code of Conduct and Ethics (the “Code”) that is rooted in our guiding principles and affirms the values and professional standards that already exist throughout Healogics. Failure to observe the Code can result in serious damage to our reputation, regulatory action and disciplinary action.
Our success requires the active participation of everyone associated with Healogics. If you know or suspect that a law, regulation, policy or our Code of Conduct and Ethics is not being followed, you must report this information. To assist you in doing this, we have appointed a Chief Compliance Officer and established a toll-free Ethics and Compliance Helpline (888-999-9460) and website Reports can be made anonymously, online or by phone and I can assure you that management will not tolerate retaliation against any employee for reporting compliance related issues or concerns in good faith to management, the Chief Compliance Officer or the Helpline.

The Board of Directors and senior executives of Healogics join me in pledging our full commitment to upholding the Code of Conduct and Ethics and the Compliance Program. I am convinced that our commitment to compliance is essential to our efforts to provide quality care, products and services to our patients and customers around the world.


Jeff Nelson, Chief Executive Officer and President