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CHILDREN’S HOSPITAL & MEDICAL CENTER CORPORATE COMPLIANCE PLAN - page 14 / 15

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ADMINISTRATION OF THE CODE OF CONDUCT

The Hospital expects each person to whom this Code of Conduct applies to abide by the Behavioral Expectations and Legal Principles set forth herein and to conduct the business and affairs of the Hospital in a manner consistent with these Behavioral Expectations and Legal Principles. Hospital Staff is expected to report conduct that is known or is suspected to be illegal or in violation of this Code of Conduct to their supervisor or to the Compliance Officer in accordance with the compliance concern reporting steps

Although Hospital Staff members are encouraged to disclose their identity when reporting conduct known or suspected to be illegal or in violation of this Code of Conduct, anonymous reports will not be refused or treated less seriously. The anonymity of the Hospital Staff member making a report will be honored to the extent possible under the circumstances. The Hospital maintains a strict policy of non-retaliation, so that no action will be taken against Hospital Staff that in good faith report on conduct known or suspected to be illegal or in violation of the Code of Conduct.

Failure to abide by this Code of Conduct or the guidelines for behavior which the Code of Conduct represents may lead to disciplinary action, up to and including termination of employment or affiliation with the Hospital. For alleged violations of this Code of Conduct, the Hospital will weigh relevant facts and circumstances, including but not limited to the extent to which the behavior was contrary to the express language or general intent of the Code of Conduct, the gravity of the behavior and the staff member’s history with the organization.

Nothing in this Code of Conduct is intended to nor shall be construed as providing any additional employment or contract rights to Hospital Staff.

This Code of Conduct is subject to revision. While the Hospital will attempt to communicate changes concurrent with or prior to the implementation of such changes, the Hospital reserves the right to modify, amend or alter the Code of Conduct without notice.

CORPORATE COMPLIANCE PLAN 5/6/10

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