BROOK FOREST DME

ETHICS & COMPLIANCE STATEMENT

At Brook Forest DME, we prioritize excellence and integrity in all aspects of our operations. Our commitment to ethical conduct and compliance with applicable laws is unwavering, as we strive to maintain the highest standards in our relationships with patients, payors, employees, and the community. To that end, Brook Forest DME operates under two foundational principles:

PATIENT CARE AND COMPLIANCE WITH ALL LAWS
(OUR “COMPLIANCE MANDATE”).

Brook Forest DME enforces a strict zero-tolerance policy regarding violations of our Compliance Mandate. All employees, contractors, and affiliates are expected to uphold the highest standards of patient care while adhering fully to all relevant legal and compliance obligations. We refuse to engage in any activities that may be deemed unethical or illegal. Our compliance program is built around seven essential elements: (1) documented standards of conduct and policies that reinforce our commitment to compliance; (2) a designated Compliance Officer responsible for oversight; (3) comprehensive compliance education and training for new employees, supplemented by annual updates; (4) mechanisms for reporting concerns and complaints without fear of retaliation; (5) prompt investigation of alleged misconduct and, where necessary, the implementation of corrective action plans; (6) ongoing auditing and monitoring to identify potential risks; and (7) thorough investigation and resolution of systemic issues, ensuring that no sanctioned individuals are part of our workforce.

To enhance our Compliance Mandate, we have adopted a robust Code of Ethics and Business Conduct (“Code”), which applies to all employees, contractors, suppliers, and officers. The Code provides essential guidance on compliance with laws, regulations, and company policies. We routinely communicate with our team about the Code to ensure understanding and adherence, requiring annual certification of commitment from all employees.

Our Code and supporting policies include anti-retaliation provisions to safeguard those who report concerns. We promote an environment of open communication, committed to protecting anyone who reports unethical practices in good faith. Any retaliation against individuals participating in the reporting process or investigations will be met with disciplinary measures.

Brook Forest DME also provides tailored ongoing training based on employee roles. This training—delivered through in-person or online formats—covers vital compliance topics such as anti-kickback statutes, false claims, Stark Law, conflicts of interest, privacy, anti-discrimination, and guidelines for gifts and hospitality. We monitor completion of required training and mandate periodic certifications from management-level employees regarding adherence to compliance policies.

Understanding the importance of effective risk oversight, Brook Forest DME is dedicated to fostering a culture of risk management, ensuring we address various risks, including competitive, legal, regulatory, operational, and financial.

In conclusion, our Compliance Program reflects Brook Forest DME’s commitment to: (1) providing the necessary education, policies, and tools for optimal patient care and legal compliance; (2) conducting thorough investigations and addressing any signs of misconduct; (3) monitoring company operations through internal audits to assess risk; and (4) adopting a proactive compliance approach to uphold our Compliance Mandate. We are steadfast in our dedication to ensuring exemplary patient care and strict adherence to all ethical standards.