Professional Documents
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Attached to help all of us is our Code of Business Conduct and Ethics (the “Code”). Our Code is a reaffirmation of
the Company’s commitment to conducting its business ethically and to observing applicable laws, rules, and
regulations. The Code reminds us of and guides us through the principles and requirements that govern our
business and behavior. When representing the Company, each employee, director, and designated agent’s
behavior must comply with and promote both the letter of the Code and its spirit of ethical conduct. Your
adherence to these ethical principles is fundamental to our future success.
The Code cannot provide definitive answers to all possible questions. Accordingly, we expect each employee,
director, and designated agent to exercise reasonable judgment to determine whether a course of action is
consistent with our ethical and legal standards and to seek guidance when appropriate. Your supervisor will often
be the person who can provide you with thoughtful, practical guidance in your day-to-day duties. We have also
appointed Patrick Cunningham as our Chief Compliance Officer, so you should feel free to ask questions of or
seek guidance from him at Patrick.Cunningham@aveanna.com.
Please read the Code carefully and make sure that you understand it. If you have any questions concerning the
Code, please speak with your supervisor or the Compliance Officer. Within five days of reading the Code, please
electronically submit your acknowledgment that you have reviewed and understood the Code and agree to abide
by its provisions. You will also be asked at least annually in succeeding years to confirm in writing your
understanding that your present and continued employment at the Company are conditioned on compliance
with the Code, that you have received and reviewed the Code, and have complied with the Code during the
preceding calendar year, commencing with the first year following adoption of the Code.
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 and 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.
The Company’s Board of Directors or a committee thereof is responsible for administering the Code. The
Board of Directors has delegated day-to-day responsibility for administering and interpreting the Code to a
Compliance Officer. Our Chief Compliance Officer has been appointed the Company’s Compliance Officer
under this Code.
The Company expects its directors, officers, employees, and designated agents to exercise reasonable
judgment when conducting the Company’s business. The Company encourages its directors, officers,
employees, and designated agents to refer to this Code frequently to ensure that they are acting within both
its letter and spirit. The Company also understands that this Code will not contain the answer to every
situation you may encounter or every concern you may have about conducting the Company’s business
ethically and legally. If you have questions or concerns about this Code or that are possibly not address in this
Code, the Company encourages each director, officer, and employee to speak with his or her supervisor (if
applicable or appropriate) and/or the Compliance Officer.
The Company’s directors, officers, employees, and designated agents generally have other legal and
contractual obligations to the Company. This Code is not intended to reduce or limit the other obligations that
they may have to the Company. Instead, the standards in this Code should be viewed as the minimum
standards that the Company expects from all of its directors, officers, employees, and certain designated
agents in the conduct of the Company’s business.
Compliance Program
Aveanna Healthcare has a robust compliance program consisting of a number of elements, including:
If you have a question, need an explanation of the Code, or want to know whether a provision of the Code
applies to a 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 toward
the Company’s customers and your fellow employees.
Reporting violations of the Code is also necessary because failure to report a violation may lead to sanctions
and disciplinary actions for encouraging, directing, facilitating, or permitting non-compliant behavior. It may
also be considered a criminal act.
Aveanna has disciplinary policies that outline expectations for assisting in the resolution of compliance issues.
While reporting violations and suspected violations is 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
400 Interstate North Parkway SE, Suite 1600
Atlanta, Georgia 30339
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 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.
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 directly to a member of the Board of Director’s Audit Committee.
Documentation of Response
Receipt of all non-anonymous submissions 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
acknowledgment 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.
However, the Company also recognizes that some people may feel more comfortable reporting a
suspected violation anonymously. If a director, officer, employee, or designated agent wishes to remain
anonymous, he or she may do so and the Company will use reasonable efforts to protect the identity of the
reporting person, subject to applicable laws, rules, and regulations and to any applicable legal proceedings. In the
event the report is made anonymously, however, the Company may not have enough information to investigate
or evaluate the allegations. Accordingly, persons who make reports anonymously should provide as much detail as
possible to permit the Company to evaluate the matter(s) set forth in the anonymous report and, if appropriate,
commence and conduct an appropriate investigation
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 with these agencies. 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 in accordance with company policies related to Professional
Conduct.
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 successful the Company will be in
protecting its 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 caused by business conditions are not
excuses 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 in accordance with the Company’s personnel policies.
Violations of this statute may result in the exclusion of the Company from participation in federal healthcare
programs. Civil fines can be up to $21,916 for each occurrence, and possible criminal felony charges carry a
$100,000 fine, ten 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, give
healthcare literature to potential patients, and participate in a public health fair. For possible exceptions,
please contact the Compliance Department.
My cousin gave me several DVD players that were store models I know that one of
my patients really likes watching movies Can
A:
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 but services from that person or
entity are billed nevertheless.
Many states have also enacted statutes like the Federal False Claims Act, which provide civil remedies for
the submission of false and fraudulent claims to state healthcare programs, including Medicaid.
Q: physician’s order for the recent visits made by the nurse Since regulations require
No It is never acceptable to backdate documents. Always date the orders for the actual
request and call the Compliance Department The Company requires all employees to
date documentation on the day written Backdating is never acceptable
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 .
Any material transaction or relationship that reasonably could be expected to give rise to a conflict of
interest should be reported promptly to the Compliance Officer. The Compliance Officer may notify the
Board of Directors or a committee thereof as he deems appropriate. Actual or potential conflicts of interest
involving a director or executive officer other than the Compliance Officer should be disclosed directly to the
Compliance Officer. Actual or potential conflicts of interest involving the Compliance Officer should be
disclosed directly to the Chief Executive Officer or to the Chief Legal Officer.
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 an employee or by members of an employee’s immediate family must be 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.
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 (such as attending a high-profile sporting event like My patient who I
the Super Bowl or other professional playoff game), may influence
your independent judgment. 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 No The gift card is
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.
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.
Third parties may ask you for information concerning the Company. Subject to the exceptions noted in the
preceding paragraph, directors, officers, employees, and designated agents (other than the Company’s authorized
spokespersons) must not discuss internal Company matters with, or disseminate internal Company information to,
anyone outside the Company, except as required in the performance of their Company duties and, if appropriate,
after a confidentiality agreement is in place. This prohibition applies particularly to inquiries concerning the
Company from the media, market professionals (such as securities analysts, institutional investors, investment
advisers, brokers and dealers), and stockholders. All responses to inquiries on behalf of the Company must be
made only by the Company’s authorized spokespersons. If you receive any inquiries of this nature, you must
decline to comment and refer the inquirer to your supervisor or to one of the Company’s authorized
spokespersons. The Company’s policies with respect to public disclosure of internal matters are described more
fully in the Company’s Disclosure Policy, which is available on the Company’s intranet.
You also must abide by any lawful obligations that you have to your former employer. These obligations may
include restrictions on the use and disclosure of confidential information, restrictions on the solicitation of former
colleagues to work at the Company, and non-competition obligations.
Corporate Opportunities
Directors, officers, employees, and designated agents owe a duty to the Company to advance its legitimate
business interests when the opportunity to do so arises. Subject to the certificate of incorporation, as
amended, of the Company, each director, officer, employee, and designated agent is prohibited from using
the Company’s property, information, or his or her own position to:
The 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.
So that the Company may comply with lobbying laws, employees must notify the Chief Compliance Officer and the Chief
Legal Officer before engaging in any activity on behalf of the Company that might be considered lobbying.
Insider Trading
Directors, officers, employees, and designated agents who are in possession of material non-public
information about the Company or other companies, including our suppliers and customers, as a result of
their relationship with the Company are prohibited by law and Company policy from trading in the
securities of the Company or such other companies, as well as from communicating such information to
others who might trade on the basis of that information. To help ensure that you do not engage in
prohibited insider trading and avoid even the appearance of an improper transaction, the Company has
adopted an Insider Trading Policy, which is distributed to employees and is also available from the Legal
Department.
If you are uncertain about the constraints on your purchase or sale of any Company securities or the
securities of any other company that you are familiar with by virtue of your relationship with the Company,
you should consult with the Compliance Officer and the Chief Legal Officer before making any such
purchase or sale.
Antitrust Laws
The Federal Trade Commission (“FTC”) and the Department of Justice (“DOJ”) enforce the US antitrust laws,
which regulate the conduct and business arrangements of corporations to promote fair competition.
Violations of antitrust laws often result in higher prices, lower quality, and fewer goods or services. It is the
intention of the antitrust laws to level the playing field and prohibit companies from enacting or engaging in
restrictive practices that limit fair competition.
The Company has specific policies regarding the above matters. Please contact People Services and/or
the Compliance Department if you have any questions.
All Company books, records, and accounts shall be maintained in accordance with all applicable regulations and standards and
accurately reflect the true nature of the transactions they record. The financial statements of the Company shall conform to
generally accepted accounting rules and the Company’s accounting policies. No undisclosed or unrecorded account or fund
shall be established for any purpose. No false or misleading entries shall be made in the Company’s books or records for any
reason, and no disbursement of corporate funds or other corporate property shall be made without adequate supporting
documentation. 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 his or her work are to be retained in accordance with applicable laws and Company policy.
The Company has specific policies regarding retention and destruction of documents, which all employees
should refer to. 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 with such reviews. For details regarding such reviews, please
contact the Chief Compliance Officer.
Communication of Code
All directors, officers, employees, and designated agents will be supplied with a copy of the Code upon its
enactment and, thereafter, upon beginning service at the Company, and will be asked to review and sign
an acknowledgment of the Code on a periodic basis. Updates of the Code will be provided from time to
time. A copy of the Code is also available to all directors, officers, employees, and designated agents by
requesting one from the Compliance Officer, or by accessing the Company’s website at aveanna.com.
1. By mailing a written description of the violation, complaint, or concern to the following address:
2. By sending a written description of the violation, complaint, or concern to the following email address:
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 of the Compliance Department
• in writing to: Chair of the Audit Committee, c/o Aveanna Healthcare Holdings Inc., 400 Interstate
North Parkway SE, Suite 1600, Atlanta, GA 30339;
• by e-mail to: Patrick.Cunningham@aveanna.com (anonymity cannot be maintained); or
• by phoning the Compliance Hotline and asking that the matter be forwarded to the Chair of the
Audit Committee.
Directors, officers, employees, and designated agents may use the above methods to communicate
anonymously with the Audit Committee. Any concerns or questions involving accounting, internal accounting
controls, or auditing should be directed to the Compliance Officer or the Audit Committee in accordance
with the Audit Committee Complaint Procedures, a copy of which is available from the Compliance Officer
upon request or available on the Company’s intranet.
Cooperation. Directors, officers, employees, and designated agents are expected to cooperate with the
Company in any investigation of a potential violation of the Code, any other Company policy or procedure, or
any applicable laws, rules, or regulations.
Misuse of Reporting Channels. Employees must not use these reporting channels in bad faith or in a false or
unreasonable manner. Further, the Compliance Hotline should not be used to report grievances that do not
involve the Code or other ethics-related issues.
Director Communications. In addition to the foregoing methods, a director also can communicate concerns
or seek advice with respect to this Code by contacting the Board of Directors through its Chair or the Audit
Committee.
Individuals who are not employees may also report concerns regarding accounting, internal accounting
controls, 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.
By signing below, I acknowledge that I have read the Aveanna Code of Business Conduct and Ethics and agree to
adhere to the policies and procedures contained therein.
_ _
Date Signature of Employee
_
Printed Name of Employee
__________________________________
Position of Employee
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subsidiaries