Statement of Ethics

Members of the CapitalFX community are expected to conduct themselves ethically, honestly and with integrity in all dealings. This means principles of fairness, good faith and respect consistent with laws, regulations and CapitalFX policies govern our conduct with others both inside and outside the community. Each situation needs to be examined in accordance with the Standards of Ethical Conduct. No unlawful practice or a practice at odds with these standards can be justified on the basis of customary practice, expediency, or achieving a “higher” purpose.

Members of the CapitalFX community are expected to exercise responsibility appropriate to their position and delegated authorities. They are responsible to each other, the CapitalFX and the CapitalFX’s stakeholders both for their actions and their decisions not to act. Each individual is expected to conduct the business of the CapitalFX in accordance with the Core Values and the Standards of Ethical Conduct, exercising sound judgment and serving the best interests of the institution and the community.

CapitalFX is committed to the principle of treating each community member with respect and dignity. CapitalFX prohibits discrimination and harassment and provides equal opportunities for all community members and applicants regardless of race, color, national origin, religion, sex, gender identity, pregnancy, physical or mental disability, medical condition (cancer-related or genetic characteristics), ancestry, marital status, age, sexual orientation, citizenship, or status as a covered veteran. CapitalFX is committed to creating a safe and drug free workplace. Following is a list of the principal policies and reference materials available in support of this standard:

• Individual Practitioners’ Code of Conduct

• Personnel Policy Manual

• CapitalFX Employee Handbook

• Personnel Policies for Staff Members

• Policies Applying to CapitalFX Activities, Organizations and Students

• Policy on Sexual Harassment and Procedures for Responding to Reports of Sexual Harassment

• CapitalFX policies on nondiscrimination and affirmative action

CapitalFX is committed to the ethical and compassionate treatment of patients and have established policies and statements of patient rights in support of this principle.

Health care facilities are subject to many of the same laws and regulations as other enterprises, as well as those particular to health entities. There are also additional requirements unique to health education. Members of the CapitalFX community are expected to become familiar with the laws and regulations bearing on their areas of responsibility. Many but not all legal requirements are embodied in CapitalFX policies. Failure to comply can have serious adverse consequences both for individuals and for CapitalFX, in terms of reputation, finances and the health and safety of the community. CapitalFX business is to be conducted in conformance with legal requirements, including contractual commitments undertaken by individuals authorized to bind the company to such commitments. The laws of Texas govern the interpretation of legal requirements.

CapitalFX policies and procedures are designed to inform our everyday responsibilities, to set minimum standards and to give CapitalFX community members notice of expectations. Members of the CapitalFX community are expected to transact all CapitalFX business in conformance with policies and procedures and accordingly have an obligation to become familiar with those that bear on their areas of responsibility. Each member is expected to seek clarification on a policy or other CapitalFX directive he or she finds to be unclear, outdated or at odds with CapitalFX objectives. It is not acceptable to ignore or disobey policies if one is not in agreement with them, or to avoid compliance by deliberately seeking loopholes.

In some cases, CapitalFX employees are also governed by ethical codes or standards of their professions or disciplines – some examples are physicians, physical therapists, occupational therapists, psychologists, nurses, rehabilitation counselors and counseling staff. It is expected that those employees will comply with applicable professional standards in addition to laws and regulations.

Employee members of the CapitalFX community are expected to devote primary professional allegiance to CapitalFX and to the mission of patient care, research and public service. Outside employment must not interfere with PRIDE duties. Outside professional activities, personal financial interests, or acceptance of benefits from third parties can create actual or perceived conflicts between the CapitalFX’s mission and an individual’s private interests. Gifts, money and/or gratuities are considered benefits and will not be accepted. CapitalFX community members who have certain professional or financial interests are expected to disclose them in compliance with applicable conflict of interest/conflict of commitment policies. In all matters, community members are expected to take appropriate steps, including consultation if issues are unclear, to avoid both conflicts of interest and the appearance of such conflicts.

All members of the CapitalFX community engaged in research are expected to conduct their research with integrity and intellectual honesty at all times and with appropriate regard for human subjects. To protect the rights of human subjects, all research involving human subjects is to be reviewed by research review boards. CapitalFX prohibits research misconduct. Members of the CapitalFX community engaged in research are not to: fabricate data or results; change or knowingly omit data or results to misrepresent results in the research record; or intentionally misappropriate the ideas, writings, research, or findings of others. All those engaged in research are expected to pursue the advancement of knowledge while meeting the highest standards of honesty, accuracy, and objectivity. They are also expected to demonstrate accountability for sponsors’ funds and to comply with specific terms and conditions of contracts and grants.

CapitalFX is the custodian of many types of information, including that which is confidential, proprietary and private. Individuals who have access to such information are expected to be familiar and to comply with applicable laws, CapitalFX policies, directives and agreements pertaining to access, use, protection and disclosure of such information. Computer security and privacy are also subject to law and PRIDE policy.

Information on the CapitalFX’s principles of privacy or on specific privacy laws may be obtained from the respective HIPPA information and CapitalFX Administrative and Procedure Manual.

The public right to information access and the individual’s right to privacy are both governed by state and federal law, as well as by CapitalFX policies and procedures. The legal provisions and the policies are based upon the principle that access to information concerning the conduct of the people’s business is a fundamental and necessary right of every person, as is the right of individuals to privacy.

Internal controls are the processes employed to help ensure that the CapitalFX’s business is carried out in accordance with these Standards, CapitalFX policies and procedures, applicable laws and regulations and sound business practices. They help to promote efficient operations, accurate financial reporting, protection of assets and responsible fiscal management. All members of the CapitalFX community are responsible for internal controls. Each business unit or department head is specifically responsible for ensuring that internal controls are established, properly documented, and maintained for activities within their jurisdiction. Any individual entrusted with funds is responsible for ensuring that adequate internal controls exist over the use and accountability of such funds.

CapitalFX resources may only be used for activities on behalf of the CapitalFX. They may not be used for private gain or personal purposes except in limited circumstances permitted by existing policy where incidental personal use does not conflict with and is reasonable in relation to CapitalFX duties (e.g. telephones). Members of the CapitalFX community are expected to treat CapitalFX property with care and to adhere to laws, policies and procedures for the acquisition, use, maintenance, record keeping and disposal of CapitalFX property. For purposes of applying this policy, CapitalFX resources is defined to include but not be limited to the following, whether owned by or under the management of the company. Cash, and other assets whether tangible or intangible; real or personal property;

• Receivables and other rights or claims against third parties;

• Intellectual property rights;

• Effort of CapitalFX personnel and of any non-CapitalFX entity billing effort;

• Facilities and the rights to use of CapitalFX facilities;

• CapitalFX’s name;

• CapitalFX records, including patient records; and

• The CapitalFX information technology infrastructure.

All CapitalFX accounting and financial records, tax reports, expense reports, time sheets and effort reports, and other documents including those submitted to government agencies must be accurate, clear and complete. All financial reports will make full, fair, accurate, timely and understandable disclosures as required under generally accepted accounting principles.

All CapitalFX staff are to use honesty and integrity at all times when discussing CapitalFX personnel, products, servicing and pricing. All personnel will maintain the highest professional standards by influencing business decisions based purely on the quality of services provided. Any promotional products used will be of minimal value and will have the approval of the Board of Directors of CapitalFX. At no time is any cash rebate acceptable for any service provided. CapitalFX is governed by HB34.

Members of the CapitalFX community are strongly encouraged to report all known or suspected improper activities under the provisions of the Policy on Reporting and Investigating Allegations of Suspected Improper Governmental Activities (Whistleblower Policy). Managers and persons in supervisory roles are required to report allegations presented to them and to report suspected abuses that come to their attention in the ordinary course of performing their supervisory duties. Reporting parties, including managers and supervisors, will be protected from retaliation for making such a report, under the Policy for Protection of Whistleblowers from Retaliation and Guidelines for Reviewing Retaliation Complaints. See the Staff Grievance Procedure outlined in the Employee Handbook.