What is an anonymous reporting hotline An anonymous

What is an anonymous reporting hotline? An anonymous hotline is a risk-free way for our employees [and vendors, patients, members, customers, etc. ] to freely report unethical or illegal activity.

Why do we need a reporting hotline? It is a best practice which allows us to: – monitor our business through the eyes of our employees [shareholders, vendors and customers] – identify potentially harmful issues early and prevent unacceptable behavior – meet regulatory compliance obligations – mitigate business risks – open the lines of communications with reporters who want to remain anonymous

Why do we need a reporting hotline? (continued) Identify and Monitor Business Risks: • • Criminal Misconduct Ethics and Compliance Financial Issues General Misconduct Harassment and Hostility Human Resources Issues Breaches of Privacy and Security Safety issues

Did you know? 71 percent of hotline users would notify their supervisor of a suspected issue, and more than half desire to remain anonymous The Association of Certified Fraud Examiners has found that a reporting hotline to be the leading method for fraud detection

Did you know? (continued) Organizations with a hotline in place on average detect fraud seven months earlier than their counterparts, reducing cost per incident by 50% According to the Fulcrum Inquiry, a third-party hotline is one of the easiest and most costeffective internal control systems an organization can implement

How does an anonymous hotline work? • We publish our ethics guidelines and inform employees on how to use the hotline (web, phone, etc. ) • Employees submit reports • Reports are anonymized and delivered to us via email • Reports are available for us to administer in a Case Management System • We investigate and resolve reports as we see fit

Features of a Comprehensive Hotline • Available 24/7/365 via: – – – • • • Toll-free access to domestic call center Web reporting Mobile app Email Fax Postal mail Multiple levels of reporter anonymity Next-day setup Worldwide access in 140 languages Daily incident reports, monthly summary reports Web-based Case Management System Promotional and instructional materials 3/7/2021 7

Why Outsource? • Available 24/7/365 • Professionally trained representatives are available in English and Spanish as well as over 140 languages • Toll-free phone access eliminates concerns over cost barriers • Allows reporters to reconnect with our hotline and anonymously continue dialog if they wish • Reports are permanently retained and easily retrieved • Using an independent third-party provider allows employees to feel confident that their anonymity will be maintained and respected • Reinforces good governance • Allows us to administer reports with an online Case Management System • Provider hosts the entire IT infrastructure 3/7/2021 8

Comparison of hotline suppliers – Features Lighthouse Services Supplier 2 Supplier 3 24/7/365 toll free phone service √ X X Live domestic operators | scripted calls √ 6 ways to submit reports √ 3 levels of reporter anonymity √ Dedicated Customer Service Representative √ Resources for: Preparation/Implementation/Ongoing Support √ Client branded web reporting pages √ Case Management System √ Exclusive client web reporting URL √ Client branded ethics hotline training video √ Promotional and instructional material √ Professionally trained staff √ Customizable collateral materials √ Rapid incident reports √ Monthly summary reports √ Company and reporter can dialog anonymously √ Web support in 36 languages √

Comparison of hotline suppliers – Features (continued) Lighthouse Services Supplier 2 Supplier 3 Phone support for 140+ foreign languages √ X X General Data Protection Regulation (GDPR) Compliant √ Domestic call center √ Global toll-free number √ Custom phone and web scripts √ Exclusive client web reporting URL √ Rapid incident reports √ Fast responses: avg. time to answer 9. 3 secs √ Permanent report retention √ Comprehensive audit trail √ Large client base with over 2, 000 active clients √

Comparison of hotline suppliers - Implementation Lighthouse Services Supplier 2 Supplier 3 Implementation Guide √ X X Easy to order collateral materials (posters, wallet cards, etc. ) √ Anonymous Hotline Implementation Letter North America √ Anonymous Hotline Implementation Letter Worldwide √ Anonymous Hotline Implementation Letter (personalized - USA) √ Anonymous Hotline Implementation Letter (personalized - Worldwide) √ Sample Web Reporting Page Introduction Examples √ Sample Hotline Policy Template √ Developing a Code of Conduct: A Step-by-Step Guide √ Developing Policies and Procedures for Conducting an Effective Ethics Investigation √ Launching a Whistleblower Hotline Across Europe √ Dedicated customer onboarding account manager

Comparison of hotline suppliers – Ongoing Support Lighthouse Services Supplier 2 Supplier 3 Client Management System (CMS) Administrators Instruction Guide √ X X General Data Protection Regulation (GDPR) Data Administration √ CMS Investigators Instruction Guide √ Investigators CMS Tutorial √ CMS Online Help √ Quarterly ethics newsletters √ No-cost ethics hotline training video for employees √ e. Learning training courses - Hands-On, Interactive Ethics and Compliance Training √ Dedicated customer support team √ Low cost √