Corporate Compliance Plan

In an effort to achieve a corporate culture of uncompromising integrity, which includes strict adherence to all applicable federal, state and local laws, and regulations, PathLabs has implemented a formal Corporate Compliance Plan (“Plan”). This Plan is available electronically or in hardcopy to all employees and was incorporated into the Employee Handbook in 2007.

The Compliance Plan was created and implemented to:

• Set Standards of Conduct for our employees, contractors and agents.

• Promote our commitment to zero tolerance for non-compliant practices.
• To detect and prevent fraud, waste and abuse in the Federal and state health care programs.
• Designate a Compliance Officer and a Compliance Committee responsible for the Program.
• Identify the education and training programs available to employees in order to implement and maintain the Program.
• Promote effective two-way communication with employees to ensure the Program is effective and provide for anonymous reporting.
• Outline monitoring activities to ensure the Program is effective.
• Describe the potential disciplinary measures for violating PathLabs’ Standards of Conduct, policies and Compliance Plan.

We are committed to exercising due diligence in seeking to prevent and detect unethical conduct, as we strive to deliver laboratory services of the highest quality.

Employee Responsibility

All employees and affiliates are responsible for the following:

• Reading and understanding the Corporate Compliance Plan.

• Understanding the rules and regulations as they apply to their jobs.
• Acting in a legal and ethical manner regarding all laws and regulations.
• Abiding by the Plan’s Standards of Conduct.
• Following the guidelines described in the Plan.
• Reporting all suspect policies, operations or practices directly to a supervisor, a person in management, Compliance Officer, or using the Compliance Hotline.
• Asking questions if there are any areas of the Compliance Plan that are not clearly understood.

Company Responsibility

The company is committed to the following:

• Harboring an atmosphere conducive to preventing, detecting, and reporting all unethical or illegal conduct that may be in violation of corporate compliance standards and procedures.
• Providing employees with training in applicable laws, regulations, policies and procedures.
• Ensure that immediate corrective action is taken when non-conformity is discovered.