1. Compliance Meetings: Honu Labs (the "Company") is committed to ensuring continuing compliance with its standards of conduct, code of ethics, and all federal, state and local laws applicable to the Company. Such laws include, without limitation, the Federal False Claims Act, the Federal Anti-Kickback Statute, the Federal Physician Self-Referral Law (referred to as The Stark Law), as well as state laws such as the Texas Patient Solicitation Act. 2. Federal False Claims Act: Anyone can violate the False Claims Act if they knowingly present or cause to be presented a false or fraudulent claim for payment to the government. In the health care context, this can take the form of insurance claims submitted to Medicare or Medicaid for reimbursement on health care goods or services. You can violate this Act or conspire with a physician to violate this Act if you knowingly assist in falsifying documentation (i.e. purchase orders, invoices, medical necessity certification, medical records) that is used as the supporting basis for the payment of claims. 3. Anti-Kickback Statute: The Anti-Kickback Statute makes it a criminal offense to knowingly and willfully offer, pay, solicit, or receive any remuneration (i.e. anything of value) to induce or reward referrals of items or services reimbursable by a Federal health care program. The statute ascribes criminal liability to parties on both sides of an impermissible, direct or indirect, “kickback” transaction. The Anti-Kickback Statute has been interpreted to cover any arrangement where one purpose of the remuneration was to obtain money for the referral of services or to induce further referrals. Violation of the statute constitutes a felony punishable by a maximum fine of $25,000, imprisonment up to five years, or both. Conviction will also lead to automatic exclusion from Federal health care programs, including Medicare and Medicaid. Examples of improper actions include giving anything of value to someone in exchange for that person ordering items or services from the Company or for encouraging the person to refer patients to the Company for items or services. Examples of "gifts" include, sporting/concert event tickets, custom-made goods, merchandise discounts, free personal services (i.e. car detailing, spa packages), high-end dining, below fair market real estate offers, and discount investment opportunities. 5. Federal Physician Self-Referral Law (The Stark Law): Stark Law prohibits physicians from making referrals for certain services (known as "designated health services") to entities in which they or their immediate family members have a financial interest. These services include, among other things, clinical lab services, physical therapy services, radiology and other imaging services, durable medical equipment and supplies, and outpatient prescription drugs. While this law is aimed at physicians, it is also often violated in conjunction with the Anti-Kickback Statute; and the Anti-Kickback Statute applies to anyone involved in an improper referral. 6. Texas Patient Solicitation Act: The Texas Patient Solicitation Act is the State's version of the Federal Anti-Kickback Statute. It is important to note that the Texas Act covers a broader range of referral types than the Federal Statute. Whereas the Federal Statute applies ONLY to referrals of items and services covered by Medicare and other government health programs, the Texas Act applies to referrals of items and services covered by ALL payors, including commercial and private plans. In Texas, your gifts to physicians or other sources of referrals can violate the law, whether or not those items or services are paid for by the government. As an employee or independent contractor of the Company, I hereby certify and acknowledge the following: I understand the Company does not participate in Medicare, Medicaid, or any other federally or state funded health care program, however, many industry participants we may come into contact with may participate in such programs; I understand and consent that compliance with the above-referenced laws is mandatory and a condition of my continued employment or service agreement with the Company; I understand my compliance responsibilities applicable to my role with the Company; I understand and have sufficient knowledge of the above-referenced laws to perform my job duties in continuing compliance of these aforementioned laws; I have not engaged in, I am not currently engaged in, and I shall not engage in conduct–including, but not limited to, giving anything of value to physicians, organizations, beneficiaries, or patients in exchange for ordering items or services from the Company (or its affiliates or entities with which it does business) or for encouraging individuals or organizations to make referrals to the Company (or its affiliates or entities with which it does business)–that is a violation of the above-referenced laws or conduct that is contrary to the Company compliance standards; I shall report any suspected conduct that is in violation of these standards and laws to the appropriate Company compliance liaison; and If I have any questions or concerns regarding these standards or laws, then I shall contact the Company compliance liaison.
The reputation and integrity of Honu Labs (the “Company”) are valuable assets that are vital to the Company’s success. Each employee contracted or otherwise, of the Company, including each of the Company’s officers, is responsible for conducting the Company’s business in a manner that demonstrates a commitment to the highest standards of integrity. The purposes of this Employee/ Distributor Code of Conduct (the “Code”) are to focus employees and contractors on areas of ethical risk, provide guidance to help employees recognize and deal with ethical issues, provide mechanisms for employees to report unethical conduct and foster among employees a culture of honesty and accountability. No code of conduct can replace the thoughtful behavior of an ethical employee. Accordingly, dishonest or unethical conduct or conduct that is illegal will constitute a violation of this Code, regardless of whether the Code specifically addresses such conduct.
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