CODE OF ETHICS

Code of Ethics (5/16)

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 TABLE OF CONTENTS

LETTER FROM THE CEO................................................................................................ 1

MISSION STATEMENT ................................................................................................... 2
GUIDING PRINCIPLES .................................................................................................... 3
QUALITY OF CLINICAL SERVICES ............................................................................. 5
BILLLING AND CODING ................................................................................................ 6
AVOIDANCE OF CONFLICTS OF INTEREST .............................................................. 7
HUMAN RESOURCES AND PAYROLL ........................................................................ 8
SAFE AND HEALTHY WORK ENVIRONMENT .......................................................... 9
NON-DISCLOSURE OF CONFIDENTIAL INFORMATION ...................................... 10
RESOURCE MANAGEMENT ........................................................................................ 11
COMPLIANCE WITH LAWS AND REGULATIONS .................................................. 12
INTERNAL CONTROLS ................................................................................................ 13
COMMUNICATION AND LINES OF AUTHORITY ................................................... 14
NON-RETALIATION ...................................................................................................... 15
COMPLIANCE INVESTIGATION AND RESOLUTION ............................................. 16
UNDERSTANDING THE EMPLOYEE’S RESPONSIBILITIES.................................. 17

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 LETTER FROM THE CEO

To All Employees of All Metro Health Care / CareGivers America:

Our mission statement and guiding principles require us to provide high quality services
to our clients while conducting our business activities in full compliance with all applicable laws
and regulations. We recognize the many challenges that all of our employees face when dealing
with the complexities of the healthcare environment. Each of you plays a very important role in
dealing with these complexities and in supporting our mission statement and guiding principles.
It is everyone’s responsibility to act in an ethical manner and to uphold the standards of
compliance outlined in this document.

We have worked together to develop this Code of Ethics for our organization. The Code,
together with the Compliance Plan, embodies our commitment to professional, ethical and legal
standards. The Code and Compliance Plan is intended to guide and direct all employees, officers,
board members and others who work at, or are associated with, our organization.

The Code and Compliance Plan helps us in making the right choices when confronted
with difficult decisions. Our organization’s reputation depends on all of us making the right
choices and taking the right actions every day. The choices that we all make are the foundation
of our organization. We all should read this Code carefully and completely, raising any questions
or concerns with our supervisors, managers, or Chief Compliance Officer. Our commitment to
compliance remains the same, regardless of our position within All Metro Health Care.

If any part of the Code of Ethics is unclear to you, or if you have questions or concerns
about a situation you are confronting, there are a number of ways to seek assistance. First, we
hope you will feel comfortable discussing your question or concern with your supervisor. If for
any reason you do not wish to do so, or your supervisor is unable to address your question or
concern, you may contact the Branch Manager or the Company’s Human Resource Director. If
these resources are either not available, or do not provide adequate answers, you can also contact
the Chief Compliance Officer at (516) 750-9194. In addition, the Compliance Hotline is
available to you. Your call will be kept anonymous to the extent possible. You may reach the
toll-free Compliance Hotline which is handled by a source outside All Metro Health Care at (800)
601-2132. On behalf of the entire Management team, I pledge my commitment that no retaliatory
action will be taken against you for reporting a compliance problem or concern in good faith
either to the hotline or through any other appropriate channel. We all have a personal obligation
to identify issues and uphold the standards described in the Code of Ethics.

Managers and supervisors have a special responsibility as part of the overall Compliance
Program. Our Management team maintains an open door policy and is ready and willing to listen
to any and all concerns, questions and suggestions that you may have regarding this Code of
Ethics or any issue.

Thank you for your continued hard work and dedication.

Yours sincerely,
David Middleton
David Middleton
CEO

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 MISSION STATEMENT

a) Maintain a high ethical standard in all transactions, while adhering to all applicable laws and
regulations;

b) Deliver high quality services;

c) Listen to the customer and focus on the customer’s needs rather than one’s own expectations.
Serve the customer, enhance the customer’s satisfaction with the Company’s services, and
survey the customer to measure the customer’s opinion about the Company;

d) Treat all employees with respect and dignity, encourage education among all employees, and
foster team work and mentoring. Do not fear success among your colleagues – encourage it;

e) Surround the Company with the best advisers available and listen to their advice. Develop
long-term partnerships with these advisers;

f) Choose vendors who are leaders in their industry. Forge long-term relationships based on
quality service, competitive rates, and accountability. Measure their performance and
communicate with them about the findings. Reward them for their good services;

g) Implement sound budgets, internal controls, and compliance standards;

h) Pursue perpetual self-improvement consistent with laws and standards of all applicable
regulating and accrediting bodies. Evaluate one’s own performance and re-evaluate it again
to ensure better results. Do not be complacent about one’s current performance – pursue
perfection in performance;

i) Improve the Company’s business processes to increase efficiency, accuracy, productivity, and
on-time performance and to ensure that the Company meets the critical requirements of its
customers;

j) Pursue increasing sales, improved margins, better financial ratios, and greater profits; and

k) Expand the Company’s role in the market as an industry consolidator. Assist the Company
by ensuring that it is a leader in all of its major endeavors. Help the Company to add value in
its relationships with employees, clients, vendors and partners.

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 GUIDING PRINCIPLES

The guiding principles of All Metro Health Care are to: a) provide high quality services; b) place
the highest priority on compliance; c) maintain effective internal controls; d) employ only
qualified employees; e) treat employees with respect and dignity; f) to pursue constant quality
improvement in all sectors of the business; and g) build on these six principles to ensure customer
satisfaction.

1. Provide high quality services:

Management of the Company believes it’s most important responsibility is to provide high
quality services to its customers (e.g., the patients, the referral sources and the payers). It
uses the following means to measure and to ensure quality of these services:
a. Audits of patient services;
b. Audits of medical records and personnel files;
c. Provision of appropriate clinical supervision; and
d. Satisfaction surveys.

2. Place highest priority on compliance:

Management believes that the Company must be in full compliance with all applicable laws
and regulations pertaining to the provision of health care services and the financial and
administrative functions. The following are the means which Management uses to achieve
this objective:
a. Audits of patient services and administrative processes;
b. Audits of medical records and personnel files;
c. Financial/management audits;
d. Implementation of the Compliance Program; and
e. Maintenance of a toll-free Compliance Hotline.

3. Maintain effective internal controls:

Management of the Company is committed to developing, maintaining, and enhancing
effective internal controls to ensure:
a. The absence of fraud and malfeasance;
b. Compliance with all applicable laws and regulations and the Company’s policies; and
c. Adherence to authorized budgets.

4. Employ only qualified employees:

Management of the Company is committed to placing only qualified employees on all health
care and other assignments. To do this, the Company conducts:
a. Criminal background and reference checks;
b. Periodic drug testing;
c. Initial and on-going orientation and education;
d. Effective supervision; and
e. Periodic evaluations and counseling of employees as needed.

5. Treat employees with respect and dignity:

Without a well-educated, hard-working, enthusiastic and loyal workforce, no company can be
a leader in its industry for a sustained period of time. Therefore, Management is committed
to developing, maintaining and enhancing competitive wages, salaries and benefits,
incentives and promotions, equal opportunity policies and affirmative action plans, worker
satisfaction programs and formal grievance procedures. Management is required to treat all

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 employees with respect and dignity. It must listen to and respond to the needs of the
Company’s employees in an effective and courteous manner. Management must also provide
appropriate supervision and mentoring of employees.

6. Continuous Quality Improvement:

The Company must deal with constantly changing variables – the needs of the community,
the expectations of patients, the diagnoses of patients, the requirements of payers, and the
aspirations of employees. Management repeatedly evaluates its own performance and that of
the Company to determine what should be reinforced or modified, and what new resources,
policies and procedures should be employed. The Company’s approach is to focus on the
needs of clients rather than on its own expectations. It employs internal audits, analyzes
outcomes, and adopts corrective measures where indicated.

7. Total customer satisfaction:

All of the money and effort that Management intends to invest in these principles will be
futile unless: a) the employees are completely devoted to the pursuit of total customer
satisfaction; and b) the clients of the Company are actually satisfied with its services and how
they are treated by the Company’s employees. The President will require that Management
and all other employees of the Company pursue total customer satisfaction as the
organization’s top priority.

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 QUALITY OF CLINICAL SERVICES

We are committed to providing quality home care and related services to our customers: the
clients, the referral sources and the payers.

a) We provide equal access to treatment and care to all clients regardless of race, color, religion,
sex, age, sexual orientation, physical or mental disability, source of payment, or other
classifications protected by law;

b) We take all reasonable steps necessary to hire and retain employees who have appropriate
and current training, experience, and competency;

c) We respect the dignity, comfort and privacy of every client, client’s family and fellow
workers and will treat all with consideration, courtesy, and respect;

d) We report to our work assignments in a timely manner and notify our supervisor/branch
manager if we are going to be tardy;

e) We promote performance improvement activities to achieve a standard of care that is a

reflection of our mission;

f) We provide client care that is appropriate, safe and in compliance with applicable
professional standards;

g) We report incidences of change in health care status of our clients to the appropriate clinical
advisor;

h) We report problems (e.g., deficiencies or errors) to those who can properly assess and resolve
the issues; and

i) We maintain the integrity and quality of our job performance.

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 BILLLING AND CODING

We are committed to billing and coding that is done accurately, on time, and in good order. We
obtain authorization as necessary for all services before they are billed. We provide services
consistent with all applicable laws and regulations, accreditation standards, prior approvals,
medical necessity, doctor’s orders, and Plans of Care.

a) We properly and timely report all time and expenses to the Local Branch Office or other
applicable departments;

b) We promptly refund any credit balances owed to a client of the Company;

c) We maintain appropriate documentation to support services rendered and billing activities;

d) We bill for services according to the guidelines provided by the payers;

e) We only bill for eligible services that have been authorized and that have been rendered and
concerning which the Company has documentation of confirmation;

f) We prepare and submit timely and accurate bills consistent with applicable laws, regulations
and policies and instructions provided by applicable regulatory agencies or their agents;

g) We educate all employees, including billing personnel, in accordance with regulatory

requirements. We ensure that employees have accurate and updated billing and coding
information; and

h) We support the Company’s periodic internal and external audits of the Company’s billing and
coding practices.

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 AVOIDANCE OF CONFLICTS OF INTEREST

All employees of All Metro Health Care avoid any conflicts of interest that might jeopardize their
ability to make independent and objective decisions, which are in the best interest of the
Company. Therefore, all employees must avoid any relationship, association, gift, favor, benefit
or transaction that might compromise the integrity of their decision-making. All employees make
ethical decisions that promote the Company and which are not based on explicit or implicit
conflicts of interest.

a) We avoid any conflicts of interest and the appearance of conflicts of interest;

b) We do not take part in any conduct that is disloyal or damaging to the interests of All Metro
Health Care’s mission statement and guiding principles;

c) We devote our work time and abilities to our assigned job responsibilities;

d) We do not participate in any extramural activities that prevent us from discharging our duties
on behalf of the Company in a loyal and proper manner;

e) We avoid all conflicts of interest and appearances of conflicts of interest. We do not use our
position at the Company to profit personally or to assist others in profiting personally in any
way that is at the expense of All Metro Health Care;

f) We do not accept or offer money or valuable gifts in exchange for the receipt of or promise of
services or goods;

g) We respect and comply with all applicable anti-kick-back laws;

h) We do not solicit a client, a client’s family, client’s friends, client’s source of referral, and/or
client’s source of reimbursement for work, favors, gifts, money or other favors. We also do
not distribute religious or political materials to any client or any client’s family, friends,
sources of referral or reimbursement; and

i) All of our activities as employees of the Company are conducted in an arms’ length manner
with the Company’s best interest in mind. We do not pursue any personal profit or personal
profit of another person at the expense of All Metro Health Care.

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 HUMAN RESOURCES AND PAYROLL

Management of the Company is committed to treating each employee with respect, dignity and
courtesy. We believe strongly in the value of investing in the on-going education and vocational
development of our employees.

a) We provide equal employment opportunities to all applicants and employees;

b) We do not discriminate in our employment practices;

c) The Company is an equal opportunity employer and has a formal affirmative action plan in
operation;

d) We do not tolerate any type of unlawful harassment in the workplace;

e) We perform background checks to screen both Field Service Workers and Associates to avoid
hiring or retaining any persons, who are currently excluded, suspended, debarred or otherwise
ineligible to participate in federal, state or local health care programs;

f) We encourage and support employees in developing their individual skills, talents and
understanding of their jobs by providing training opportunities as well as evaluating our work
processes to improve performance;

g) Our employees, Branch Managers, and Senior Management maintain an open-door policy
and we do not allow any act of retaliation against employees who in good faith report a valid
concern and/or violation of a law, regulation, or Company policies;

h) We carry out appropriate disciplinary measures when a violation occurs;

i) We encourage the reporting of payroll or benefit issues to the Local Branch Office, the
representative of the Department of Payroll Services, or the Finance Department; and

j) We utilize exit interviews and/or post employment survey processes to ensure that we provide
exiting employees with further opportunities to discuss compliance concerns.

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 SAFE AND HEALTHY WORK ENVIRONMENT

The Company is committed to creating and maintaining a safe and healthy work environment for
all of its employees. All employees of the Company support the Company’s commitment. The
well-being of each employee is important to the management of this organization.

a) We implement policies and procedures to keep our facilities safe;

b) We comply with applicable laws and regulations relating to the environment, including those
laws and regulations regarding the handling, storage, use, and disposal of hazardous materials
and infectious wastes;

c) We comply with permit requirements for the safe discharge of pollutants into the air, sewage
systems, water, and land;

d) We are committed to maintaining a work environment free of alcohol and illegal drugs;

e) We become familiar with and follow emergency and safety plans and procedures;

f) We report any possible violation of the organization’s safety policies and procedures, laws,
regulations, or standards to the manager or supervisor of the worksite. If we are not satisfied
that the issue has been addressed, we notify the individuals responsible for safety through the
Chief Compliance Officer; and

g) We report all work-related injuries to our supervisor in the Local Branch Office.

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 NON-DISCLOSURE OF CONFIDENTIAL INFORMATION

We are committed to protecting each employee’s and each client’s right to privacy in accordance
with the applicable laws and regulations, including HIPAA.

a) We respect the privacy of our clients and colleagues. We recognize we have access to the
information of others on a “need to know” basis in accordance with our assigned
responsibilities;

b) We take reasonable steps to limit the use of, disclosure of, and requests for health information
to the minimum necessary to accomplish the intended purpose, unless otherwise permitted by
law;

c) We do not reveal medical, clinical, or business information unless such release is supported
by a legitimate clinical or business purpose, client authorization or acknowledgement of
receipt of privacy notice, or court or agency order and is in compliance with applicable laws,
rules, regulations, as well as our policies and procedures;

d) We treat individual salary, benefits, payroll, personnel files, and information on disciplinary
matters as confidential information;

e) We allow the release of information by appropriate staff members to third parties only if the
disclosure is permissible by law and/or the individual has completed appropriate
authorization forms;

f) We maintain security of the information stored on paper and electronically and transmitted on
our computer systems; and

g) We report confidentiality violations to the Privacy Officer or those who can properly assess
and resolve the issues.

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 RESOURCE MANAGEMENT

We are committed to protecting property, equipment and our resources against loss, theft or
misuse.

a) We believe the practice of selling, trading, transferring, or scrapping of property without the
appropriate approval is considered a misuse of assets;

b) We safeguard the organization’s property, equipment, supplies, services, and other assets.
We have systems within our areas of responsibility to protect these items from theft or
misuse;

c) We respect and protect the intellectual property rights of individuals and companies with
which we do business. We follow applicable copyright, patent, trademark, and marketing
laws and license agreements when we use computer software and printed publications;

d) We do not install, share, or copy software programs or perform any other acts that would be
in violation of the vendor’s software license agreements or of organizational policies;

e) We report all hours worked properly and accurately in accordance with our time and
attendance policies and procedures; and

f) We devote our work time and our abilities to our assigned job responsibilities.

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 COMPLIANCE WITH LAWS AND REGULATIONS

The Company is committed to operating in accordance with all applicable laws and
regulations, conducting business ethically and honestly, and acting in a manner that improves the
Company’s standing in the community. All employees are required to support this policy
including the following:

a) We comply with the regulatory requirements, accreditation standards, and organizational

policies governing the creation, management, retention and destruction of records;

b) We issue and maintain financial and cost reports, accounting records, research reports,
expenses accounts, time sheets, and other documents that accurately and clearly reflect
transactions and financial performance;

c) We do not participate with competitors or others in any activities that may illegally limit
competition;

d) We do not use nor tolerate any other employee using client drugs or controlled substances in
a manner which is illegal;

e) We attend all educational courses and other activities sponsored by the Company intended to
advance our knowledge of applicable laws, regulations, and accreditation standards;

f) We initiate improvement activities and corrective measures as needed based on information

we receive through our commitment to continuous quality improvement and risk management
activities; and

g) We report any violation or potential violation of applicable laws, regulations, and Company
policies following the Company’s established chain of command or to the Company’s Chief
Compliance Officer.

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 INTERNAL CONTROLS

All Metro Health Care seeks to create and to maintain a system of checks and balances to ensure
that the Company’s administrative and accounting policies are followed by all employees.

a) We ensure that only authorized employees execute business transactions;

b) We ensure the appropriate reporting and documentation of business transactions to enable

accurate preparation and reporting of financial and other records;

c) We record all assets, liabilities, and transactions in accordance with generally accepted
accounting principles;

d) We do not falsify records in any manner;

e) We make commitments to and expend funds only in accordance with applicable laws and
regulations and consistent with the Company’s budgets and expense guidelines;

f) We report knowledge or suspicion of any inaccurate or false records to the appropriate

managers or the Compliance Hotline;

g) We support and cooperate with the Company’s need to conduct both scheduled and surprise
audits of clinical, operational, administrative and financial activities of the Company; and

h) We implement appropriate safeguards and adopt all necessary corrective measures whenever
those safeguards do not work as intended.

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 COMMUNICATION AND LINES OF AUTHORITY

The Company encourages each employee to communicate directly and frequently with his or her
direct supervisor and with Senior Management of the corporation. If an employee is concerned
about a violation or potential violations of this Code of Ethics, other policies, applicable
laws/regulations, and/or accreditation standards, he or she should report immediately his or her
concern first using the established chain of command. However, if the employee is
uncomfortable using the chain of command, he or she may speak directly to any of the following
managers or resources of the Company:

a) Clinical or business supervisor;

b) Branch Manager or manager of an administrative department;

c) Vice President of Human Resources;

d) Director of Risk Management;

e) Director of Patient Services;

f) Chief Compliance Officer;

g) President; or

h) Compliance Hotline

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 NON-RETALIATION

The Company will not tolerate any retaliation in response to an employee reporting in good faith
a breach or potential breach of this Code of Ethics, any applicable laws/regulations, accreditation
standards, or policies of the Company. However, demonstrably false accusations will result in
severe disciplinary action by the Company up to and including termination of one’s employment.
Any employee who believes that he or she has suffered retaliation for reporting a breach or
potential breach should contact the Company’s Chief Compliance Officer (or to a member of the
Compliance Committee if the source of the retaliation is the Chief Compliance Officer).

a) We report in good faith any knowledge or suspicion of breaches of this Code of Ethics, any
applicable laws/regulations, accreditation standards, or policies of the Company; and

b) We report to the Company’s Compliance Officer if we believe we have been subject to

retaliation for reporting a breach or potential breach.

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 COMPLIANCE INVESTIGATION AND RESOLUTION

The Chief Compliance Officer will ensure the prompt and thorough investigation of all suspected
violations and will coordinate appropriate follow-up action and resolution as indicated. All
investigations will be conducted following established procedures for confidentiality. The
purpose of the investigation is to:

a) Identify situations in which applicable laws, regulations, standards, or Company policies may
not have been followed;

b) Identify individuals who may have knowingly or inadvertently acted in a non-compliant

manner;

c) Facilitate the correction of any violations or misconduct;

d) Implement procedures necessary to ensure future compliance to protect the Company in the
event of civil or criminal enforcement actions; and

e) Preserve and protect the Company’s assets.

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 UNDERSTANDING THE EMPLOYEE’S RESPONSIBILITIES

The following summarizes what each employee’s responsibilities are with respect to this Code of
Ethics:

a) We are trustworthy, honest, faithful and reliable in everything we do while representing All
Metro Health Care;

b) We follow all applicable federal, state and local laws and regulations;

c) We seek to know the laws, rules and regulations, and Company policies that apply to our
jobs. We seek additional education, advice, and guidance if we have any questions about
such laws, rules, regulations, and Company policies;

d) We keep client information and corporate information confidential in accordance with

applicable legal and ethical standards;

e) We avoid all conflicts of interest and appearances of conflicts of interest. We do not use our
position at the Company to profit personally or to assist others in profiting personally in any
way that is at the expense of All Metro Health Care,

f) We do not accept or offer money or valuable gifts in exchange for the receipt of or promise of
services or goods,

g) We use the resources of the Company efficiently and as directed by the Management of the
corporation. We protect the assets of All Metro Health Care against loss, theft, or misuse;

h) We are committed to providing quality care and reliable services to the Company’s clients;

i) We foster a safe, healthy, and wholesome work environment at the Company and encourage
other employees to do the same;

j) We use our best efforts to obtain all necessary prior approvals and other authorizations to
ensure that the Company has the necessary documentation to confirm its authorization to
provide services and to bill for said services;

k) We use our best efforts to charge, code, and invoice accurately and on time, including
providing documentation to support the services provided and the amounts billed;

l) We are committed to treating all clients and employees of the Company with respect, dignity
and courtesy. We foster team work among our fellow colleagues;

m) We seek advice of our immediate supervisor or the Chief Compliance Officer if we are
uncertain of the legality of any action or event; and

n) We report in good faith any breach or potential breach of this Code of Ethics or any
applicable law/regulation, accreditation standard, or Company policy using the Company’s
chain of command and, if necessary, reporting directly to the Chief Compliance Officer or the
Company’s Hotline.

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