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Anodyne, LLC ("Anodyne") is dedicated and committed to meeting high ethical standards and complying with all applicable laws in all activities regarding the provision of diabetic shoes and/or inserts.  To ensure Anodyne achieves this operating goal, it has established a Corporate Compliance Program, as outlined in a Compliance Plan ("Compliance Plan"), designed to create and foster an organizational culture encouraging open communication regarding compliance issues, without fear of retaliation, which is embraced by every Anodyne employee and/or vendor who furnishes services or provides items to Anodyne (in this Code of Conduct, each such person is referred to as "you" or "your").


In addition to Anodyne's general policies and procedures and the Employee Handbook, this Code of Conduct summarizes the standards of behavior expected of you.  To the extent that all individuals associated with Anodyne act responsibly, Anodyne's reputation as an ethical and lawful organization will be protected.  Acting responsibly means that, at all times, you will:  (1) perform your duties in a manner that upholds and complies with the principles set forth in this Code of Conduct, the Compliance Plan and all Anodyne policies, procedures, guidelines and instructions; (2) ensure your conduct meets the requirements of all relevant federal, state, and local laws and regulations; (3) take responsibility for your behavior (including both acts and omissions); and (4) immediately report anything that you believe to be inconsistent with the principles of this Code of Conduct.  You will be notified of any material changes to this Code of Conduct.


No set of policies can substitute for good judgment and common sense, nor can a single set of policies cover every difficult circumstance that arises.  The complexity of the health care environment can sometimes make it difficult to recognize behavior or practices that may be illegal or improper.  At Anodyne, maintaining a culture of compliance means, in part, that if you have a question about something, if you are uncertain as to what the right course of conduct is in any situation, or you observe any potential compliance issue, you are obligated to report this to Anodyne's Compliance Officer ("Compliance Officer").  It is the policy of Anodyne that no person will suffer any adverse effect on his or her job or career advancement as a result of raising an ethical or legal concern in good faith.


Compliance with this Code of Conduct is a condition of employment and a prerequisite for affiliation or doing business with Anodyne.  Violations of this Code of Conduct will be grounds for discipline, up to and including immediate termination of your employment or affiliation with Anodyne.  Consistent with its policies, Anodyne shall not engage in or permit any action of retaliation or reprisal to be taken against an employee who, in good faith, reports suspected and/or actual misconduct.


PRINCIPLE 1Legal and Ethical Conduct: You are required, as a condition of your employment or affiliation with Anodyne, to comply with all applicable laws and regulations, standards and other requirements imposed on our business by any level of government or certifying agency.  Without limiting the generality of that statement, you must follow and satisfy all requirements of the federal and state laws and regulations.  In particular, you shall ensure that you do not make any statements or create any documentation that is false, fraudulent, inaccurate or fictitious in connection with Anodyne.  Anodyne will not tolerate any falsification of any records.  Similarly, Anodyne will not pursue any business opportunity that requires engaging in unethical or illegal activity.


Anodyne and its personnel shall engage in fair, honest, respectful, dignified and ethical relationships among and outside Anodyne.  You must be honest in doing your job or fulfilling your duties, and maintain the highest ethical professional standards, judgment and objectivity.  In particular, Anodyne seeks positive relationships with health care providers and government programs.  Positive relationships require ongoing communication.  In very practical terms, this means you must perform you duties in a way that promotes the public's trust in Anodyne—and you.


Your integrity is paramount, and it is everyone's collective responsibility to maintain Anodyne's institutional integrity and reputation.  You must be honest and forthright in any representations made to health care providers, vendors, contractors, other employees or agents, and the community.  You shall not use or reveal, for any personal or financial gain, any proprietary or confidential information concerning Anodyne.


PRINCIPLE 2Conflicts of Interest: You should avoid situations that could result in a conflict of interest.  You shall not have other jobs that interfere with your ability to perform your duties at Anodyne.  Just as importantly, you must avoid any activity that conflicts with the interests of Anodyne, or that even creates the appearance of impropriety.  In particular, promoting business with any entity with which you have a familial or other personal or business relationship may constitute a conflict of interest.  You must make a disclosure in advance to the Compliance Officer and obtain written approval from the Manager prior to proceeding with the transaction.  If you suspect that a conflict may exist or be created, then you should consult with or notify the Compliance Officer. Similarly, any issue you observe with respect to vendors and contractors shall immediately be reported to the Compliance Officer.


PRINCIPLE 3Workplace Environment: Work rules were created to protect us all.  Anodyne's personnel are expected to comply with Anodyne's rules and to immediately report violations of these policies to a supervisor or the Compliance Officer.  In addition, all persons associated with Anodyne must respect each other as human beings.  Anodyne's personnel shall show proper respect and consideration for each other, regardless of position or station.  Discriminatory treatment, harassment, abuse or intimidation will not be tolerated.  Anodyne is a drug free workplace in accordance with its policies. If you experience significant differences in professional judgment with another person, you should talk to a member of the management team and/or the Compliance Officer to resolve it.