Our goal is to model integrity in all that we do. To that end PHTS has implemented a corporate
integrity program and our Code of Business Conduct that serves as the “constitution” of the Corporate
Integrity Program. Our Corporate Integrity Program is modeled on the U.S. Sentencing Commission Guidelines for
Organizations and compliance program guidance documents published by the U.S. Department of Health and Human
Services Office of Inspector General.
Our Code of Business Conduct and the PHTS Corporate Integrity Program apply to PHTS associates,
the board of directors, and our strategic and business allies, when representing PHTS.
Although common sense and common decency are reliable enough guides for conducting business,
we have formally adopted an integrity program to make it clear that we have high expectations of all
those who work for us and do business with us.
Specifically, we have clear operational policies, and firm non-discrimination and anti-harassment
policies. Our integrity program, overseen by the PHTS Integrity Officer, extends to confidentiality
of records, compliance with laws and regulations, and maintaining appropriate relationships, among
others. We also provide several channels, including a hotline, for our associates or others to report
concerns without fear of retaliation or retribution.
Concerns may be reported to Cindy J. Moore, AIM, CQIA, CQA, chief quality officer at PHTS at

or 803.731.5300. Those who wish to remain
anonymous may contact the PHTS Corporate Integrity Hotline Website at
www.hotlineservices.com.