Standards of Conduct:

• HCM (the “Company”) is committed to protecting and promoting the rights of all residents and to providing care and services necessary to obtain or maintain highest practicable physical, mental and psychosocial well-being and quality of life to our residents.  To achieve these goals, the Company’s personnel shall monitor their performance against the standards established by Medicare, Medicaid and applicable State regulation.
  
• Personnel shall assure that all residents have the right to a dignified existence, self-determination, and communication with and access to people and services inside and outside the facility.
  
• Individuals, who by State or Federal law are deemed inappropriate to work in a nursing home, shall not be employed.
  
• The Company’s strongest asset is a reputation for integrity and honesty.  Achieving business results by illegal acts or unethical conduct is unacceptable.  Personnel shall act in compliance with the requirements of applicable law, this Code and in a sound ethical manner when conducting business.  The Company shall conduct its business in conformance with sound ethical standards.
  
• The Code shall be distributed to all personnel setting forth general standards applicable to business operations.  In addition, there are a number of more detailed and specific policies covering particular business units or subject matters.  These policies shall be communicated to applicable personnel.  If you wish to review any policies, please contact your supervisor.
  
• Each Manager/Supervisor is responsible for ensuring that personnel within their supervision are acting ethically and in compliance with applicable law and the Code.  All personnel shall be responsible for acquiring sufficient knowledge to recognize and report potential compliance issues.
  
• Personnel shall not offer or give any bribe, payment, gift, or thing of value to any person or entity with whom the Company has or is seeking any business or regulatory relationship except those which are legal and given in the ordinary course of business.  If given for purposes of receiving something in return, this activity is illegal and is strictly prohibited.
  
• Personnel shall not accept any bribe, payment, gift, item or anything of value from any person or entity with whom the Company has or is seeking any business or regulatory relationship.  Personnel must promptly report the offering or receipt of gifts or anything of value.
  
•  All political activities relating to the Company shall be conducted in full compliance with applicable law.  No Company funds or property shall be used for any political contribution or purpose unless first approved by the Chief Operating Officer.  Personnel may make direct contributions of their own money to political candidates and activities, but these contributions will not be reimbursed.  Personnel shall not directly or indirectly authorize, pay, promise, deliver, or solicit any payment, gratuity, or favor for the purpose of influencing    any political official or government employee.  Personnel shall not entertain government personnel in connection with Company business.
  
• Personnel shall be completely honest in all dealings with government agencies and representatives.  No misrepresentations shall be made, and no false bills or requests for payment or other documents shall be submitted to government agencies or representatives.  Personnel certifying the correctness of records submitted to government agencies, including bills or requests for payment, shall have knowledge that the information is accurate and complete before giving such certification.
  
• Personnel shall not have a financial or other personal interest in a transaction between the Company or any of its business units and a vendor, supplier, provider, or customer other than a fair market value transaction.  Personnel shall not engage in any financial, business, or other activity which competes with the Company’s business which may interfere or appear to interfere with the performance of their duties or that involve the use of Company property, facilities, or resources.
  
• All of the Company’s business transactions shall be carried out in accordance with management's general or specific directives.  All of the books and records shall be kept in accordance with generally accepted accounting principles or other applicable principles.  All transactions, payments, receipts, accounts, and assets shall be completely and accurately recorded on the Company’s books and records on a consistent basis.  No payment shall be approved or made with the intention or understanding that it will be used for any purpose other than that described in the supporting documentation for the payment.  All information recorded and submitted to other persons must not be used to mislead those who receive the information or to conceal anything that is improper.
  
• Personnel shall comply with applicable antitrust laws.  There shall be no discussions or agreements with competitors regarding price or other terms for services, prices paid to suppliers or providers, dividing up customers or geographic markets, or joint action to boycott or coerce certain customers, suppliers, or providers.
  
• The Company and its personnel shall not engage in unfair competition or deceptive trade practices, including misrepresentation of the Company’s services or operations.  Personnel shall not make false or disparaging statements about competitors or their services or attempt to coerce suppliers or providers into purchasing services.
  
• All personnel shall maintain the confidentiality of the Company’s business information and of information relating to the Company’s vendors, suppliers, providers, employees and residents.  Personnel shall not use any such confidential or proprietary information except as is appropriate for business.  Personnel shall not seek to improperly obtain or to misuse confidential information of the Company’s competitors.
  
• Books and records shall be created, maintained, retained, or destroyed in accordance with the Company’s records management policy.
  
•  All personnel shall be responsible for ensuring that the work environment is free of discrimination or harassment due to age, race, gender, color, religion, national origin, disability, sexual orientation, or covered veteran status.  Any form of harassment, including the creation of a hostile working environment, is prohibited.
  
• All personnel shall follow safe work practices and comply with all applicable safety standards and health regulations.