Code of Conduct

Table of Contents

1. Our Mission and Values Guide Us
   
   • Our Mission & Values
   • Code of Conduct Purpose
   • Responsibilities
   • Duty To Report
2. Respect in the Workplace
   
   • Anti-Discrimination
   • Anti-Harassment
   • Company Resources
   • Environmental Health and Safety
3. Corporate Responsibility & Regulatory Requirements
   
   • Quality of Patient Care
   • Preventing Fraud, Waste, and Abuse
     
     • Gifts, Meals, and Entertainment
   • Conflicts of Interest
   • Medical Necessity and Laboratory Testing Services
   • HIPAA, Privacy, and Security
   • Sanction Screening and Exclusions
   • Competitive Practices
   • Charitable and Political Contributions

Our Mission and Core Values Guide Us

At Solaris Diagnostics, we are driven by a singular, unwavering goal: to set the gold standard for excellence in healthcare diagnostics. Our vision is a healthcare landscape where precision, compassion, and innovation converge to provide exceptional patient care. This is our North Star, the guiding principle that shapes our every endeavor.

Precision in Diagnostics

Our foremost aim is to redefine precision in diagnostics. We are committed to delivering results that healthcare practitioners and patients can rely on with absolute confidence. Precision means more than just accuracy; it means providing the right information at the right time to inform critical medical decisions.

Compassionate Patient-Centric Care

We believe that healthcare should never lose sight of the human element. Our ideal goal is to make every patient’s diagnostic journey as stress-free, supportive, and personalized as possible. We want to be more than a lab; we want to provide comfort and reassurance during challenging times.

Building Strong Healthcare Partnerships

We envision a future where Solaris is not just a diagnostic service provider but a trusted partner for healthcare practitioners. We aim to strengthen our relationships with healthcare professionals, fostering collaboration and trust. Together, we can improve patient outcomes and drive healthcare forward.

We define ourselves by our values.

Our Values speak to who we are, and what we stand for:

1. Compassion for the Patient – Behind every sample is a patient, and every patient deserves our compassion.
2. Collaborate with Integrity – Always choose to collaborate ethically and with respect, starting with honest communication.
3. Accountable Actions – Be responsible for what you say, then accountable for what you do.
4. Accurately Efficient – Accuracy and efficiency are equally possible by following the right processes.
5. Learn to Solve – Bring solutions to every challenge by learning from experience and feedback.
6. Stay Nimble – Be ready to think, decide, and act quickly when customization is required.

Our values help us make decisions that are consistently in the best interests of our patients, communities, colleagues, and the Company. Doing the right thing is your responsibility and so is following this Code of Conduct.

Code of Conduct Purpose

The Solaris Code of Conduct is a key part of the Compliance Program. It reflects core values and principles that guide Solaris operations. The purpose and objective of the Code is to:

• Establish a code of standards to be followed by all employees and contractors;
• Communicate an overview of standards they are expected to follow;
• Communicate methods of reporting issues and concerns in order to prevent, detect, and correct activities that are not consistent with the ethical standards Solaris has adopted; and
• Document the Solaris commitment to high professional standards.

The Code is the cornerstone of our anti-fraud and regulatory initiatives. It is designed to prevent and identify potential occurrences of unethical activities and to direct you to sources for more information.

Scope

The Solaris Code of Conduct must be followed by all Solaris employees and contractors. No one, no matter what his or her employment position, is exempt from the standards established by the Code. Failure to comply is a serious matter that may lead to disciplinary action up to and including termination. In addition, employees who violate some specific laws may be subject to legal prosecution.

We also expect our vendors to follow the highest ethical standards and to report any suspected violation of the Code. The reporting mechanisms available to our employees are also available to our vendors.

Responsibilities

All Employees and Contractors

All employees are required to be familiar with and follow the standards set forth in the Code of Conduct. On an annual basis, you should review the Code of Conduct and complete annual compliance training. If you are an employee, you must acknowledge you have received a copy of the Code at your annual performance review. You must also attest that you are aware of the principles it contains and your responsibility to report anything that may violate those principles. Compliance is an element of your performance review considered in merit increases, promotions, etc.

Special Responsibility for Managers & Leaders

With leadership comes additional responsibility. While all employees are expected to follow our Code of Conduct, a leader sets the example for employees to follow. In addition, leaders should create an environment that encourages discussion of our ethical standards and values. As a leader, make sure that:

• Your conduct is consistent with the highest ethical and legal standards.
• Your employees are aware of our policies including Compliance, Human Resources, the Lab, and other departmental policies.
• Your employees are aware of their obligation to report suspected violations of our standards.
• You know when to escalate concerns that were reported to you that could violate the Code of Conduct. Some may require legal obligations such as refunds or compliance corrective actions.
• You create a work environment that is open and receptive to discussion and reports of possible violations.
• You prohibit retaliation against anyone who reports a potential violation to you.

Duty To Report

All employees have a responsibility to ask questions and raise concerns about compliance or ethical behavior. If you know of a possible violation, you have a responsibility to report it to your supervisor. If you are uncomfortable for any reason in reporting a violation to your supervisor or if you believe your supervisor has not appropriately addressed the issue, you may report the suspected violation to any member of Solaris management, Human Resources, the Compliance Officer, or the Compliance and Ethics line at 844.860.8388 or Solaris.ethicspoint.com. The Compliance and Ethics line is an independent company where issues may be reported anonymously.

The Company is committed to identifying and correcting any wrongdoing, so it will promptly investigate all reported concerns. Employees and contractors are expected to fully cooperate with all investigative efforts and, to the extent possible, confidentiality will be maintained consistent with our legal and ethical responsibilities.

If the investigation substantiates a violation, corrective action will be taken. Corrective actions can include changing Company policies to prevent such a violation in the future, instituting appropriate disciplinary action against employees, and/or notifying an appropriate governmental agency.

Non-Retaliation

Solaris will not tolerate retaliation against anyone for speaking up in good faith about misconduct, including a violation of the Code of Conduct or company policy. Retaliation may be direct or indirect and takes many forms including dismissal, demotion, threats, harassment, or discrimination. If you think you or someone else has been the victim of retaliation, report it to one of our many reporting channels.

Respect in the Workplace

Solaris is committed to fostering a trusting and safe work environment, ensuring dignity, fairness, and integrity in how we treat not only patients and clients but each other in all of our interactions. Reports of inappropriate behavior may be made to a supervisor, Human Resources, any member of management, the Compliance Officer, or the Compliance and Ethics hotline at 844.860.8388.

Anti-Discrimination

We treat employees equally regardless of background. Solaris prohibits treating anyone unfairly in matters that involve recruiting, hiring, training, promoting, compensation, or any other term or condition of employment. Employment decisions must always be in compliance with the law and based on merit, qualifications, and job-related performance without regard to non-job-related characteristics such as:

• Race, color, or ethnicity
• Ancestry, or national origin
• Disability
• Sex, gender, or gender identity
• Marital status or pregnancy
• Age
• Religion
• Sexual orientation
• Veteran status
• Any other legally protected status

Anti-Harassment

Employees should feel comfortable in the workplace. Harassment includes unwelcome verbal, visual, physical, or other conduct of any kind that creates an intimidating, offensive, or hostile work environment. We seek to create a work environment that is free from harassment of any kind, offensive, or disrespectful conduct. Examples of unacceptable behavior include:

• Sexual harassment
• Offensive language or jokes
• Racial, ethnic, gender, or religious slurs
• Degrading comments
• Intimidating or threatening behavior
• Unwanted physical activities (e.g., touching, hugging, or blocking someone’s path)
• Showing hostility towards others

It’s important to remember that harassment, sexual or otherwise, is determined by how your actions impact others—regardless of intentions.

Company Resources

We rely on you to manage Company resources honestly and efficiently. Company resources are intended for legitimate business purposes. You also have a responsibility to protect our equipment and other resources from theft, loss, damage, waste, or abuse. Protecting Company funds is particularly important if you have spending authority, approve travel and entertainment expenses, or manage budgets and accounts. You must always:

• Ensure Company funds are properly used for their established business-related purpose
• Obtain required approval before incurring an expense
• Accurately record all expenses in Company books and records
• Verify compliance with our policies

Environmental Health and Safety

Maintaining a safe and healthy workplace is everyone’s responsibility. Solaris has expectations that all employees:

• Take an active role in promoting your own safety. Observe safe work practices, obey posted warning signs, and wear personal protective equipment whenever it is required. Follow all applicable regulations and procedures when disposing of waste.
• Immediately report to your supervisor any workplace injury, activity, or condition that could pose a threat to your personal safety or put anyone at our workplace at risk of injury or accident. If an incident requires medical attention or the assistance of law enforcement, seek help immediately.
• Report any known or suspected violations of these policies. Also, report any environmental non-compliance, or other concern or condition that may cause harm.

For a Closer Look:

• The Employee Handbook
• Bloodborne Pathogen Exposure Control Plan and other Laboratory Policies

Corporate Responsibility & Regulatory Requirements

All of our processes, decisions, and actions must be driven by integrity. We are honest and forthright in all our dealings with customers, patients, and each other. We comply with the laws and regulations governing our complex business—not only as a legal obligation but because it is the right thing to do.

You have a responsibility to understand and follow the regulations and policies that apply to your job. This includes laws that pertain to clinical laboratories that seek reimbursement from the Medicare and Medicaid programs and laws that pertain to relationships between our Company and referral sources such as physicians, hospitals, and nursing homes.

There are various laws that apply to our business, including:

• The Anti-Kickback Statute
• The Stark Law
• The False Claims Act
• The Civil Monetary Penalties Statute
• Clinical Laboratory Improvement Amendments (CLIA)
• HIPAA Privacy and Security Regulations
• State False Claims Acts

Our Compliance Policies are based on these laws, but it should not be assumed that a policy violation is a violation of the law, as the company uses them as a basis for high standards aligned with the mission and values.

Quality of Patient Care

Our foremost aim is to redefine precision in diagnostics in every part of the patient care process—from the order, specimen collection, transportation, testing, and results communication. It is crucial to our mission to set the gold standard in patient-centric healthcare diagnostics through precision, compassion, and innovation.

To make sure we maintain the highest quality:

• Follow all policies and procedures. If you think an approved policy doesn’t work well, raise the issue with your Supervisor. Don’t take it upon yourself to modify the way things are done without changing the procedure.
• Understand and follow the CLIA, State, and any Accreditation requirements relevant to your job. Those requirements include but are not limited to:
  • Performing tests only with written authorization of a physician or other individual authorized under state law to order laboratory testing.
  • Releasing test results only to an authorized person.
  • Obtaining the necessary CLIA certificates before performing a test.
  • Ensuring adherence to CLIA, State & Accreditation requirements when participating in proficiency testing surveys.

Speak Up

If you see a violation of procedures or anything else that makes you uncomfortable, raise it to your supervisor, manager, or Laboratory Director. The Duty to Report applies to quality and all areas of this Code of Conduct.

For a Closer Look:

• Test Order Policy
• Laboratory Policies

Preventing Fraud, Waste, and Abuse

Interactions with Healthcare Providers

We do not engage in any conduct that is intended to, or has the appearance of, improperly influencing a
healthcare provider’s judgment. We follow all federal and state laws listed above that govern our
relationships with healthcare providers. These laws can be very complicated and strict so it’s vital that our
policies are followed in relationships with current or potential referral sources and that such relationships
are known.

Even if financial relationships with referral sources are appropriate, if a proper agreement is not in place or
the details of that agreement are not being followed, laws could be implicated. Always be cautious in any
situation where we are providing, buying or selling anything other than clinical lab testing from an actual
or potential client.

In-Office Specimen Collectors

The Federal Anti-kickback Statute says that providers cannot offer remuneration of any kind in exchange for referrals of federal health care program beneficiaries. This means when labs supply Collectors, to physician offices, those Collectors must be careful to avoid any situation in which they perform tasks unrelated to the lab’s services or in any way provide a benefit to physicians to induce referrals to the lab.

Solaris may place a Collector in a client’s office when internal criteria are met. The duties of the Collector must be restricted to the collecting and processing of specimens for Solaris and the completion of necessary paperwork or computer work in order to submit specimens, report results, facilitate inquiries, and/or bill tests on behalf of Solaris. Upon employment with Solaris and before the Collector is placed in the client’s office, the Collector signs a Collector Agreement that is maintained in his/her personnel file.

Client Supplies

Solaris furnishes certain laboratory supplies to clients whenever the supplies are used solely for the purpose of collecting, processing, and transporting specimens to Solaris. The quantities of such supplies that are provided to a client must be consistent with the volume of specimens Solaris reasonably expects to receive from the client. Solaris does not offer supplies for use in a client’s own in-house laboratory, or for other functions that are not directly related to the laboratory tests that are performed by Solaris. Solaris may not offer volume discounts that it receives from vendors to clients.

What Should I Do?

Clients or Potential Clients

Federal and state laws and our policies limit what we may give our clients or potential clients in the way of gifts, entertainment, promotional items, and other hospitalities and courtesies. Our Gifts, Entertainment, and Promotional Items Policy prohibits giving gifts to our customers or potential customers. Modest business meals and entertainment are permissible if:

• It is promoting Solaris services.
• A Solaris representative attends the meal or entertainment with the client or potential client.
• The cost and frequency are moderate.
• New or continued business is not an implicit or explicit condition of the meal or entertainment.
• The value of the entertainment would not exceed the annual dollar limits provided in our policy.
• Prior to sharing a meal or entertainment with a client or potential client, the Stark total spend should be checked to ensure the annual limit has not been reached.

Patients

There are also rules about giving gifts and things of value to patients. Solaris should not influence patients to use our lab or a particular provider by providing gifts, entertainment, cash, or cash equivalents. The company should not routinely waive patient co-pays and deductibles. There are annual dollar limitations that can be permitted in certain circumstances. There are also permitted exceptions such as:

• Items and services tied to medical care for financially needy patients.
• Preventative care services.

Vendors

You must not accept gifts, favors, services, entertainment, cash/cash equivalents, or other things of value if the acceptance influences or creates an impression of influencing decision-making.

You may retain gifts of nominal value from suppliers if you exercise good judgment and discretion in accepting gifts. To the extent possible, these gifts should be shared with co-workers. Solaris does not define a “nominal” value. Rather, you should exercise good judgment in accepting gifts and seek advice from your Manager or Compliance Officer if in doubt.

Meals, refreshments, and entertainment with current or potential vendors are permitted so long as they are infrequent, of nominal value, and in an appropriate setting consistent with Solaris values.

In general, Solaris employees may not accept vendor-sponsored travel. However, there may be times when special training is required, and the cost of travel is included in purchase agreements. Accepting vendor-sponsored travel should be approved in advance by the Compliance Officer.

For a Closer Look:

• Gifts, Entertainment & Services Policy
• Indigent Patient Billing Resources
• Relationships with Referral Sources Policy
• Specimen Collector/Phlebotomy Policy