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Code of Business Conduct and Ethics

Table of Contents

Our Mission Statement and Core Values

 

Mission Statement

To revolutionize the way pediatric healthcare is delivered, one patient at a time.

 

Core Values

Compassion
Team Integrity
Accountability
Trust
Innovation
Compliance Fun

 


To All Aveanna Team Members:

The Aveanna mission is to revolutionize the way Pediatric Healthcare is delivered, one patient at a time. We believe that the cornerstones of this revolution are our core values. Guiding principles such as integrity, accountability, trust, and compliance shape the foundation of all the standards by which we operate. As a result, we have developed the Aveanna Code of Business Conduct and Ethics, as well as our Aveanna Compliance Program. Every team member, including our Executive Team and our Board of Directors, will go through the exact same training, which will ensure that we have a consistent culture throughout the organization.

As you approach your Compliance and Code of Conduct training, keep in mind that this is not your “check the box” program that is done once a year; this is our way of life. We use the principles outlined in this training in every decision that we make, each and every day. By doing this three hundred and sixty five days a year, we believe we will differentiate ourselves from our competitors.

Good luck with your training and good luck in incorporating these principles into your everyday work experience. Thank you for choosing Aveanna as your employer and welcome to the Aveanna Team.

Tony Strange, CEO and President Ron Windley, Chairman of the Board

 

 

 

 


 

Aveanna Healthcare Values

Commitment to Professionalism

“The unique function of the nurse is to assist the individual, sick or well, in the performance of those activities contributing to health or its recovery (or to peaceful death) that he would perform unaided if he had the necessary strength, will, or knowledge. And to do this in such a way as to help him gain independence as rapidly as possible.”
– Virginia Henderson

As professionals, we strive to inspire confidence in those we serve. We treat our patients, their families and our colleagues in a professional manner. Our desire is to work collaboratively in the best interests of those we serve, to promote their independence with respect for and deference to the dignity of all. To this end, we will refrain from gaining any personal benefit or taking any advantage at the expense of our patients, their families, or other members of their personal and social networks.

As an Aveanna Healthcare TRUSTED Employee, I pledge to:

  • Treat each patient and family with respect and dignity
  • Refrain from any action that might be harmful to the quality of life or health of those for whom I care
  • Use all my knowledge, skill, and understanding to practice my profession in accordance with the highest standards of that profession
  • Support and collaborate with fellow healthcare team members
  • Trust others and promote relationships based on trust and integrity
  • Ensure that all personal information entrusted to me is held safely and in the strictest confidence
  • Delineate and maintain professional boundaries, and abstain from inappropriate involvement with my patients and the personal relationships of my patients’ families
  • Care for my patients in a non-judgmental manner
  • Act in the best interest of my patients and their families at all times
  • Refrain from obtaining personal gain at my patients’ expense
  • Enhance my skills and knowledge through continued education and application to the most current clinical, ethical, and compliance standards that prevail in our industry and professions today

 

Introduction

This Code of Business Conduct and Ethics (the “Code”) applies to all the directors, officers and employees of Aveanna Healthcare, Inc., its subsidiaries and the entities controlled by it (the “Company”). Compliance with the Code is required by all employees. It is an integral part of every employee’s job function and an element of performance evaluations for supervisory-level employee. Any illegal or unethical action or the appearance of misconduct by anyone acting on the Company’s behalf is unacceptable, so the Code should also be followed by the Company’s agents and representatives, including any consultants.

The Code is not intended to cover every situation that you might encounter. In many cases, more specific requirements are contained in various corporate policies, procedures and guidelines, including the Company’s Policy Manual, which can be obtained from the company intranet or your supervisor or the Compliance Department. In addition to the Code, the Company has also adopted a comprehensive compliance program.

In addition to providing a copy of the Code to new employees, the Code is posted on the Company’s internet and intranet sites, and portable devices in the home. The distribution of any changes to the Code and all other Company policies is the responsibility of supervisory-level employees.

 

Compliance Program

Aveanna Healthcare has a robust Compliance Program consisting of several elements, including:

  • A system to identify compliance risk areas
  • Annual self-evaluation based on audit results (internal and external), hotline calls, and investigation results
  • A process to respond to identified risk areas
  • A process for correcting compliance problems promptly and thoroughly
  • A process for implementing corrective actions via updated policies, procedures, and systems to reduce potential for recurrence
  • Compliance Training at orientation and annually that meets all Deficit Reduction Act and CMS requirements
  • Reasonable level of resources devoted to address identified gaps, identify solutions, implement solutions, and re-review to ensure problem is fixed

 

Compliance Process

Where to Go With a Question or Concern or to Report a Violation

If you have a question, need an explanation of the Code, or want to know if a provision of the Code applies to a particular situation, the best place to start is with your supervisor, the Compliance Department, or the Chief Compliance Officer.

If you believe any employee is violating the Code or otherwise acting, or potentially acting, in an illegal or unethical manner, you must report it. Doing so shows your sense of responsibility and fairness to the Company’s customers and your fellow employees.

Reporting violations of the Code is also necessary because failure to report a violation can lead to sanctions and disciplinary actions for encouraging, directing, facilitating or permitting non-compliant behavior. It can also be considered a criminal act.

Aveanna has disciplinary policies that outline expectations for assisting in the resolution of compliance issues. While all reports of violations and suspected violations are strongly encouraged; it is unacceptable to knowingly file a false or materially misleading report.

Potential violations of the Code or other Company policies, or any concerns or complaints may be reported
to the Chief Compliance Officer or the Compliance Department in one of the following ways:

  1. By mailing a written description of the violation, complaint, or concern to the following address:
    Aveanna Healthcare
    Six Concourse Parkway, Suite 1100
    Atlanta, Georgia 30328
    Attn: Chief Compliance Officer
  2. By sending a written description of the violation, complaint, or concern to the following e-mail address:
    compliance@aveanna.com
  3. By calling the following hotline number and leaving a message describing the violation, complaint, or
    concern:
    1-800-408-4442
  4. By reporting the violation, complaint, or concern in person to the Chief Compliance Officer or a
    Compliance Department team member.

Individuals who are not employees may also report any concerns by using one of the methods above. Potential violations by the Compliance Department of the Code or other Company policies should be reported directly to the Chairperson of the Audit Committee by mailing a written description to the physical address above, Attn: Chairperson of Audit Committee. If you choose, potential violations, or concerns may be reported anonymously.


 

Treatment of and Response to Submissions

Review and Response

The Chief Compliance Officer and/or a member of the Compliance Department will check the mailbox, e-mail address, and hotline on a regular basis and respond to all submissions where the reporter is contactable. The Chief Compliance Officer, with the assistance of the Compliance Department, will determine the appropriate means of addressing the concerns or complaints, and will investigate any reported violations and determine if any disciplinary and/or other corrective action should be taken. The Chief Compliance Officer will report, in writing, all violations, complaints or concerns contained in the submissions to the Audit Committee in executive session. The Audit Committee will perform an independent and objective assessment of the violation, complaint, or concern and of any response.

In appropriate circumstances, the Chief Compliance Officer will have the authority and discretion to bring any submission immediately to the attention of the Audit Committee or to the Chairman of the Audit Committee. In addition to any action taken by the Chief Compliance Officer or the Compliance Department, the Audit Committee will take such action as it deems necessary or appropriate to address any violation, concern, or complaint, including obtaining outside counsel or other advisors to assist the Audit Committee.

 

Q: My office passed out our annual required compliance training tests and assessments with the answers already filled in on the answer key and asked me to just sign my name on the answer sheet. I am not going to take the annual compliance course; I’m just signing my name. Since this is the same test I took on hire, is this okay?

A: No. It is never okay to sign your name on something that you did not do. The purpose of the annual compliance course is to remind all employees of their responsibilities with regard to compliance. Should this or something like this occur, it is your responsibility to notify the Compliance Department.

Follow-up

The Chief Compliance Officer is the designated contact person for individuals who wish to follow up on their submissions. If, after discussion with the Chief Compliance Officer, you are not satisfied with the response to the issue, you may report the matter to another member of the Compliance Department or directly to a member of the Audit Committee.

Documentation of Response

Receipt of all submissions (that are not anonymous) will be responded to either orally or in writing, unless indicated otherwise. All compliance-related messages left on the hotline and all submissions (written and oral) will be maintained in a confidential file by the Chief Compliance Officer for a minimum of seven years following receipt. The Chief Compliance Officer will also maintain a record of each response, including the date of the acknowledgement and any other actions taken. Such records shall be maintained confidentially. Access to the confidential file will be restricted to the Chief Compliance Officer, the Compliance Department, members of the Audit Committee, and individuals specifically designated by the Audit Committee.

 

Protection from Retaliation or Intimidation

Essential to the success of the Code is open communication by all employees of concerns, complaints, and questions relating to any aspect of compliance or business ethics without fear of retribution or retaliation. The Company will not tolerate retaliation or intimidation in any form against any employees who, in good faith, report any concern, or illegal or unethical conduct. Any retaliation or intimidation will be cause for disciplinary action, up to and including termination of employment (of the retaliator). You may report retaliation concerns using the same procedure described above for reporting concerns, complaints, and violations.

 

Discipline for Violations

All employees are expected to comply with all provisions of the Code and with all of the Company’s other corporate policies. Compliance is a condition of continued employment. The Company intends to enforce the provisions of the Code and its other policies strictly, vigorously, and consistently. Any violation of the Code or the Company’s policies will be dealt with promptly in compliance with existing policies and procedures for managing personnel issues. Violations of the Code include, but are not limited to, failing to report a violation, condoning a violation by someone else, making a knowingly false report, and retaliating against or intimidating another person who reports a suspected violation in good faith. Anyone who violates the Code or the Company’s policies will be subject to disciplinary action, up to and including termination. Disciplinary actions will be firmly, consistently, and fairly enforced with all levels of personnel.

 

Waivers

In certain extraordinary situations, a waiver of a provision of the Code (other than matters required by law) may be granted. Contact the Chief Compliance Officer if you believe special circumstances warrant a waiver of any of the Code’s provisions. The waiver request should be made prior to the contemplated action. Any waiver of the Code for executive officers or directors can be made only by the Company’s Board of Directors and must be promptly and publicly disclosed as required by law.

 

Responding to Investigations and Legal Action

All employees are required to cooperate with internal investigations. You must never destroy or alter any documents or electronic records, lie or mislead an investigator, or obstruct the collection of information relating to an investigation or legal action brought on behalf of, or against, the Company.

The Company will cooperate with government agencies responsible for investigating suspected violations of law. If requested by the Company, you are also required to cooperate. You must notify the Compliance Department or the Legal Department immediately if you learn that a government agency or a third party is conducting such an investigation or asking for information pertaining to a suspected violation of law. Failure to cooperate will be addressed following company policies related to Professional Conduct.

 

Compliance with the Law

The Company is engaged in a highly regulated business; and includes laws, regulations, and rules
governing healthcare programs. It is the Company’s policy that its business be conducted in accordance with all applicable laws and regulations in a manner that will reflect a high standard of ethics. The Company requires its employees and agents to comply with all applicable laws, rules, and regulations where the Company does business. Violations of laws and regulations may subject an individual, as well as the Company, to civil and/or criminal penalties.

In order to comply with the law, employees and agents must learn enough about the laws that affect the Company in order to (a) identify potential issues, (b) know when and where to seek advice, and (c) obtain proper guidance on the correct way to proceed. Employees are strongly encouraged, and have an obligation, to raise concerns if they suspect some violation of the law or if they are uncertain as to the proper legal course of action.

The earlier a potential problem is detected and corrected, the more likely the Company will be in successfully protecting the Company’s business and reputation. Where there is any doubt as to the lawfulness of any activity, advice should be sought from the Company’s Chief Compliance Officer, in consultation with the Compliance Department and/or the Legal Department.

Perceived pressure from supervisors or demands due to business conditions is not an excuse for violating the law.

Compliance with the law does not comprise our entire ethical responsibility; rather, it is a minimum essential condition for performance of our duties.

Failure to comply with the law will be managed according to the company personnel and people services policies.

 

Anti-Kickback Statute

Federal healthcare programs such as Medicare and Medicaid are covered by an anti-kickback statute. You cannot pay a physician, hospital, payer, or vendor either cash or gifts in exchange for patient, supplies, or equipment referrals to the Company. In turn, they cannot pay you to take patients or provide supplies or equipment from them. Also, if you know, or should have known, that an item could induce a purchase by a patient eligible for Medicare or Medicaid, this is also a violation of the anti-kickback statute. Violations of this statute may result in exclusion of the Company from participating in federal healthcare programs. Civil fines can be up to $21,563 for each occurrence, and possible criminal felony charges carry a $25,000 fine, five years imprisonment, or both. There are exceptions (safe harbors) to this statute that reflect reasonable business practices. For example, you can provide refreshments at an open house or give healthcare literature to potential patients and participate in a public health fair. For any possible exceptions, please contact the Compliance Department.

 

Q: My cousin gave me several DVD players that were store models. I know that one of my patients really likes watching movies. Can I give him one of the DVD players?

A: No. Even though you didn’t pay for the DVD player, it has value and could possibly influence the patient to continue service with the Company rather than changing to a competitor.

Physician Self-Referral Law (Stark Law)

The Stark Law prohibits physicians from referring Medicare or Medicaid patients to a healthcare provider with which the physician or an immediate family member of the physician has a financial relationship. In addition, it prohibits healthcare providers from billing for such services. The Stark Law is specific to Medicare and Medicaid; however, similar state laws may apply to private payer patients, and additional Federal laws may apply in these situations. There are exceptions to the Stark Law that allow physicians to conduct reasonable business practices. Please contact the Compliance Department to discuss any concerns or issues.

 

Q: I know of a physician who refers all of her Medicare and Medicaid patients to a home health agency where her husband is clinical supervisor. Can we bill for the services that we provide to her patients?

A: No. The Company cannot bill Medicare or Medicaid for services to patients who are referred to a healthcare provider with which the immediate family member of the physician has a financial relationship.

False Claims Act

The Federal False Claims Act prohibits knowingly making a false claim against the government. False claims can take the form of overcharging for a product or service, delivering less than the promised amount or type of service, underpaying money owed to the government, and charging for one thing but providing another. False claims also occur if a person or entity is excluded from the Medicare / Medicaid program, and services from that person or entity are billed.

Many states have also enacted statutes like the Federal False Claims Act that provide civil remedies for the submission of false and fraudulent claims to state healthcare programs, including Medicaid.

Q: During the weekly billing review my supervisor identified that there was no physician’s order for the recent visits made by the nurse. Since regulations require that all orders are obtained prior to services being delivered, my supervisor asked me to write an order and backdate it to before the services were provided. Is that okay?

A: No. It is never acceptable to backdate. Always date the orders for the actual day you received them. Notify your supervisor that you are not able to comply with her request and call the Compliance Department. The Company requires all employees to date documentation on the day written.

Backdating is never acceptable.

 

Health Insurance Portability and Accountability Act (“HIPAA”)

Employees must comply with state and federal laws that govern the confidentiality of certain patient information, including HIPAA, which regulates the use and disclosure of patient health information. All employees come into contact with personal health information at some time in their employment with the Company. HIPAA applies whether you work in the field or whether you work at a Company location or Service Center and provide billing services. Should you become aware of a breach in the confidentiality of personal health information, you must report it immediately to the Company Privacy Officer, The Security Officer, or the Compliance Department.

Federal and state laws also require that the Company maintain certain business and patient records for minimum periods of time. All employees are also required to comply with the Company’s document retention policies and procedures. Personnel who engage in violations of the Anti-Kickback Statute, False Claims Act, or HIPAA will be managed according to company policies.

 

Q: I know that my supervisor takes home records that contain protected health information at night to work on them. We are now missing a portion of that paperwork. What should I do?

A: Notify your up-line manager and the Compliance Department as soon as you learn of the lost paperwork. The Company must report any breach of protected health information to the United States Department of Health and Human Services. Patients’ medical records should not be removed from the office. The only exception is in the event of a disaster according to our Disaster Policy or under subpoena.

Conflict of Interest and How to Avoid It

General Guidance

A “conflict of interest” occurs where an individual’s private interest interferes, or even appears to interfere, with the interests of the Company. Conflicts of interest often occur when you receive an improper personal benefit as a result of your position with the Company.

Relationships with prospective or existing suppliers, contractors, customers, competitors, or regulators must not affect your independent and sound judgment. Business decisions and actions must be based on the best interests of the Company and must not be motivated by personal considerations or relationships. In addition to the general need to prevent conflicts of interest, the Company is subject to laws and regulations controlling contractual and other relationships with sources of referrals to the Company or recipients of referrals from the Company. Such matters are discussed in more detail in the Company’s Conflict of Interest Policy.

General guidelines to help you better understand several of the most common examples of situations that may cause a conflict of interest are discussed below. Employees are required to disclose to the Chief Compliance Officer or the Compliance Department any situation that may be, or may appear to be, a conflict of interest.

 

Outside Employment

Any outside activity must be strictly separated from your employment with the Company and should not harm job performance at the Company. In addition, the Company is subject to laws and regulations strictly controlling contractual and other relationships with sources of referrals to the Company or recipients of referrals from the Company. Such matters are discussed in more detail in the Company’s Policy Manual.

 

 

Q: I work as a field therapist with the Company. Do I need to tell my supervisor that I also own my own outpatient therapy business?

A: Yes. Referrals are made to outpatient businesses on a regular basis. A referral to your outpatient therapy business would benefit you financially. It is important that your supervisor and the Compliance Department are aware of your private business so they can discuss the conflict of interest issues with you and implement any necessary processes to protect patients and the Company.

Board Memberships

Employees, other than officers and directors, who desire to serve on the board of directors or a similar body for an outside company or government agency must obtain prior approval of the Compliance Department. Officers and directors should contact the Legal Department prior to joining the board of directors of any outside company. Helping the community by serving on boards of non-profit or community organizations is encouraged and does not require prior approval.

 

Family Members and Close Personal Relationships

Employees may not use personal influence to direct Company business to an entity in which any family member or friend has an interest. All employees must disclose to the Chief Compliance Officer (and/or Compliance Department) any interest held by them with any entity doing business with the Company, including interests held by their immediate family (except for ownership of less than 1% of a public corporation). In addition, employees must disclose arrangements such as consulting or part-time employment or other dealings with such an entity. The employment of any family member or friend of employees by such entity must also be disclosed. Such information will not automatically be regarded as a conflict of interest, but it must be disclosed to allow the Company to determine if any undue or special influence could appear to be involved. The Company can then decide what action it should take to safeguard its interests.

 

Investments

Employees may not allow their personal investments to influence, or appear to influence, their independent judgment on behalf of the Company. Any employees who own any interest in any corporation or entity that directly or indirectly competes with the Company or any division or affiliate of the Company must so advise the Chief Compliance Officer. Any holdings of less than 1% in a public corporation whose stock is regularly traded on a stock exchange do not have to be reported; however, interests held in excess of that amount or in any private entity by employee or by members of the employee’s immediate family must be so disclosed. If there is any doubt about how an investment might be perceived, it should be disclosed to the Chief Compliance Officer and/or Compliance Department.

 

Gifts and Entertainment

Small gifts and entertainment can help build relationships with business employees. However, employees must be careful to avoid giving or receiving gifts or entertainment intended to influence judgment or create a feeling of obligation. No gift or entertainment should ever be offered, given, provided, or accepted by employees or family members of employees unless it (1) is not cash, gift certificates, or other “cash in kind”; (2) is consistent with customary business practices; (3) is not excessive in value; (4) cannot be construed as a bribe or payoff; and (5) does not violate any laws, regulations or Company policies. Employees may not accept kickbacks, lavish gifts, or gratuities.

Q: When I visit a referral source, I like to bring them Starbuck’s coffee as a treat. If one day I am unable to bring the coffee, can I give them a $5.00 Starbuck’s gift card instead?

A: No. Although the $5.00 Starbuck’s card is of nominal value, it is considered “cash in kind,” which is prohibited by law.

Employees may accept items of nominal value, such as small promotional items bearing another company’s name. In some situations, it would be impractical or harmful to refuse or return a gift. When this happens, discuss the situation with the Chief Compliance Officer or a member of the Compliance Department. Some business situations call for giving gifts. The Company’s gifts must be legal, reasonable, and approved by management. Employees may never pay bribes or provide any cash or “cash in kind” to any person. Employees may not provide any gift if it is prohibited by law, Company policy, or the policy of the recipient’s organization.

In general, employees may accept entertainment that is reasonable in the context of the business. For example, accompanying a business employee to a local cultural or sporting event, or to a business meal, would in most cases be acceptable. Entertainment that is lavish or frequent may influence your independent judgment (such as attending a high-profile sporting event such as the Super Bowl or professional playoff games). Accepting entertainment that may appear inappropriate should be approved by the Compliance Department in advance of accepting such entertainment. Employees may provide entertainment that is reasonable in the context of the business.

The giving and receiving of gifts and entertainment are discussed in more detail in the Company’s Policy Manual. Employees, other than directors and officers, should contact the Chief Compliance Officer or the Compliance Department if you have questions about the appropriateness of any gift or entertainment. Directors and officers should discuss such questions and concerns with the Company’s General Counsel and / or the Compliance Department.

 

Q: My patient who I have been taking care gave me a $100 gift card to Applebee’s as a thank you for the services she received. Can I keep the gift card?

A: No. The gift card is considered “cash in kind” and could be considered a payment for services provided. Nominal gifts like flowers, candy or cookies can be accepted.

Travel

Employees may participate in business-related functions and activities that have a valid business purpose, are customary to the Company’s business, and have no special significance attached to them. Participation in these events should not be excessive in scale, expense, or frequency.

In general, employees may accept transportation and lodging provided by a Company supplier or other third party if the trip is for business and is approved in advance by the employee’s supervisor.

Unless prohibited by law or the policy of the recipient’s organization, the Company may pay the transportation and lodging expenses incurred by customers, agents, or suppliers in connection with a visit to a Company facility or product installation. The visit must be for a business purpose and must be approved in advance by the Compliance Department.

 

Confidential, Proprietary Information

All confidential information or proprietary information of the Company must be protected. Confidential or proprietary information includes, for example, pricing, inventions, technology developed for use by the Company, clinical protocols, financial data, trade secrets and know-how, acquisition and divestiture opportunities, marketing and sales programs, research and development information, and customer and supplier information. In addition, information relating to a patient’s identity, healthcare history, diagnosis, condition, treatment or evaluation is confidential information that must be protected at all times and may only be disclosed in accordance with HIPAA and other laws. Confidential information also includes information that suppliers and customers have entrusted to us.

Employees should not disclose confidential or proprietary information to anyone within or outside of the Company unless the recipient will generally need this information to carry out his or her assigned responsibilities as an employee of the Company, or as an outsider who has been properly authorized to receive such information.

Inquiries from the press, media, or the public regarding the Company should only be answered by the employees designated to respond to such inquiries. The obligation not to disclose confidential or proprietary information continues after employment with the Company terminates.

 

Taking Company Business Opportunities

Employees may not take for themselves opportunities that rightfully belong to the Company. Opportunities rightfully belong to the Company when, for example, the Company has pursued the opportunity, when it has been offered to the Company, when it is the kind of business the Company competes in, when the Company has funded it, or when the Company has devoted facilities or personnel to develop it.

 

Protection and Proper Use of Company Assets

Employees should protect the Company’s assets and ensure their efficient use. Theft, carelessness and waste have a direct impact on the Company’s profitability. All Company assets, which include the Company name, the Company’s trade names and materials bearing these names, should be used for legitimate business purposes only and not for any unlawful, improper, or personal purpose. Company assets and equipment should only be used for Company business, although incidental personal use of assets, such as telephones and computers, may be permitted in limited circumstances.

 

Political Contributions and Political Lobbying Activity

Political contributions by the Company or in the name of the Company are prohibited without prior approval of the General Counsel. “Political contributions” mean direct or indirect payment in support of political candidates, officeholders, or political parties. In addition to cash payments, political contributions are deemed to include work performed by employees during paid working hours; the purchase of tickets to fundraising events; the payment for advertising, printing or other campaign expenses and product donations.

This policy applies solely to the use of Company assets, such as telephones and computers, and is not intended to discourage or prevent individuals from making political contributions or engaging in political activities on their own behalf, so long as such contributions or activities are not linked in any way to the Company. Employees will not be reimbursed directly or indirectly by the Company for personal political contributions.

Laws of certain jurisdictions require registration and reporting by anyone who engages in lobbying activity. Generally, lobbying includes the following:

  1. Communicating with any member or employee of the legislative branch of government for the purpose of influencing legislation
  2. Communicating with certain government officials for the purpose of influencing government action
  3. Engaging in research or activities to support or prepare such communication

So that the Company may comply with lobbying laws, employees must notify the General Counsel before engaging in any activity on behalf of the Company that might be considered lobbying.

 

Fair Dealing

No employee should ever use any illegal or unethical method to gather competitive information. Stealing proprietary information, possessing trade secret information that was obtained without consent, or inducing such disclosures by past or present employees of other companies is prohibited. Furthermore, employees are required to comply with the antitrust and unfair competition laws of the United States and the other countries in which the Company operates or does business. Employees who question whether a contemplated action may violate fair competition laws should speak to the Compliance Department or the Legal Department.

 

Equal Employment Opportunity and Non-Discrimination

The Company is an equal opportunity employer and is committed to promoting a diverse workplace environment where individual differences are appreciated and respected. It is the Company’s policy to recruit, hire, train, and promote employees regardless of their race, color, national origin, religion, gender, sexual orientation, disability, age, or any other basis protected by Federal or state law. In addition, the Company does not tolerate discrimination against employees based on any of these factors.

 

Responsibility to Company Personnel

The Company is committed to treating all employees with honesty, fairness, and respect, and providing a safe and healthy work environment. Abusive, harassing, or offensive conduct is unacceptable, whether verbal or physical. Examples include derogatory comments based on racial or ethnic characteristics, and unwelcome sexual advances. Employees are directed to report harassment when it occurs. Furthermore, the Company is committed to providing all employees with a safe and secure environment. Employees will comply with all health and safety laws, regulations, and Company policies governing health and safety. Employees are responsible for immediately reporting accidents, injuries, and unsafe equipment, practices, or conditions to a supervisor or other designated person.

The Company has specific policies regarding the above matters. Please contact People Services and/or the Compliance Department if you have any questions.

 

Accuracy and Retention of Business Records

Accounting standards and applicable federal and state laws and regulations require that transactions and events relating to the Company’s assets and operations be properly recorded in the books and accounts of the Company and accurately reported in the applicable reports to regulatory agencies. All disclosures made in reports to regulatory agencies or in communications to the public must be full, fair, accurate, timely, and understandable. To accomplish this result, all financial employees shall make and retain books, records, and accounts that, in reasonable detail, accurately, completely, and objectively reflect transactions and events, and conform both to required accounting principles and to the Company’s systems of internal controls. No false or artificial entries may be made. No entry may be made or recorded in the Company’s books and records or reported in any disclosure document that misrepresents hides or disguises the true nature of the event or transaction, and all entries and reports must be made in a timely manner.

All employees are responsible for immediately reporting any concern about the Company’s financial records and its accounting, internal accounting controls, and auditing procedures to the Chief Compliance Officer or a member of the Compliance Department.

The Company has specific policies regarding accuracy and retention of business records. Please contact the Compliance Department if you have any questions.

 

Document Retention

All documents (in whatever form or medium) and other records created or received by any employee in connection with their work are to be retained in accordance with applicable laws and Company policy. The Company has specific policies regarding retention and destruction of documents. Refer to these policies for guidance regarding the retention of documentation. Employees should consult the Legal Department for questions related to the Company’s document retention guidelines.

 

Compliance Reviews

The Company undertakes reviews of compliance with the Code and other policies and procedures from time to time. The nature and timing of general reviews are determined by the Audit Committee of the Company’s Board of Directors and the Chief Compliance Officer.

All employees are expected to cooperate in connection with such reviews. For details regarding such reviews, please contact the Chief Compliance Officer.

 

Enforcement of the Code

The Audit Committee of the Company’s Board of Directors has ultimate oversight responsibility with respect to the Code and ultimate oversight responsibility for ensuring that the Code and the Company’s corporate policies will govern all business activities of the Company. To assist the Audit Committee in this undertaking, the Company has established the senior management position of Chief Compliance Officer and a separate Compliance Committee. Among other things, the Chief Compliance Officer is charged with monitoring compliance with the Code and all federal healthcare programs. In addition, the Company’s Compliance Committee is comprised of various members of senior management from different business functions within the Company, and is primarily charged with the review of compliance matters and supporting the Chief Compliance Officer in fulfillment of his or her duties. Once again, potential violations of the Code or other Company policies, concerns, or complaints may be reported to the Chief Compliance Officer or the Compliance Department in one of the following ways:

  1. By mailing a written description of the violation, complaint, or concern to the following address:
    Aveanna Healthcare
    Six Concourse Parkway, Suite 1100
    Atlanta, Georgia 30328
    Attn: Chief Compliance Officer
  2. By sending a written description of the violation, complaint, or concern to the following e-mail address:
    compliance@aveanna.com
  3. By calling the following hotline number and leaving a message describing the violation, complaint, or
    concern:
    1-800-408-4442
  4. By reporting the violation, complaint, or concern in person to the Chief Compliance Officer or a
    Compliance Department team member.

Individuals who are not employees may also report concerns regarding accounting, internal control, and auditing matters by using one of the methods above. Potential violations of the Code or other Company policies by the Compliance Department should be reported directly to the Chairperson of the Audit Committee by mailing a written description to the physical address above, Attn: Chairperson of Audit Committee. If you choose, potential violations or concerns may be reported anonymously.


Aveanna Healthcare is committed to following all legal, ethical, and compliance laws and regulations, but the only way we can do this is to depend on our employees, officers, and directors to do the right thing.