Code of Business Conduct

Overview

This Code of Business Conduct (the “Code”) serves to guide all directors, officers, employees, and representatives of Wounds Plus—including all affiliated entities and subsidiaries—in maintaining the highest standards of honesty, integrity, and ethical conduct in all business dealings. Our mission is to deliver exceptional, compassionate mobile wound care services, and our values must be reflected in every action we take.

1. Honest and Ethical Conduct

Wounds Plus is committed to operating with integrity and professionalism in all interactions—with patients, families, partners, vendors, and within our own teams. Every team member is expected to perform their duties ethically and uphold the trust placed in us by those we serve.

2. Corporate Practice of Medicine

In accordance with applicable state and federal law, Wounds Plus strictly prohibits any non-licensed individual—including directors, officers, and administrative employees—from interfering with clinical decisions or the independent judgment of licensed medical professionals. All medical decisions must be made solely by credentialed professionals such as physicians, nurse practitioners, and physician assistants, without influence from Wounds Plus leadership or operations personnel. Wounds Plus is fully committed to legal and ethical compliance in the delivery of medical services.

3. Conflicts of Interest

All employees, officers, and directors are expected to act in the best interest of Wounds Plus. A conflict of interest arises when personal interests could interfere with professional responsibilities. These conflicts must be promptly disclosed to leadership or compliance staff for review. Even the appearance of a conflict must be taken seriously and transparently addressed.

4. Corporate Opportunities

Employees and leadership must not take personal advantage of business opportunities discovered through company resources or relationships. Use of Wounds Plus property, information, or influence for personal gain is strictly prohibited unless specifically approved by the Board of Directors. All employees are expected to advance the legitimate interests of Wounds Plus whenever possible.

5. Business Entertainment and Gifts

While professional relationships are important, employees may not accept or offer gifts or entertainment that may create real or perceived conflicts of interest. No employee may accept cash or cash-equivalent gifts from patients or vendors. Patient gifts should be infrequent, under $15 per instance, and must not exceed $75 in a calendar year. Gifts must never be offered to government officials or payers. All interactions must preserve transparency and trust.

6. Legal and Regulatory Compliance

Wounds Plus complies with all applicable laws and regulations, including but not limited to:

• HIPAA and patient privacy laws

• Medicare/Medicaid billing and documentation requirements

• Anti-kickback and referral laws (e.g., Stark Law)

• State and federal licensure and scope-of-practice regulations

• Accurate financial reporting in accordance with GAAP

All employees must understand and follow relevant laws and policies in their roles and are encouraged to seek guidance when unsure.

7. Reporting Violations and Enforcement

Wounds Plus encourages a culture of accountability and open communication. Employees who suspect any violations of this Code, legal misconduct, or unethical behavior should report concerns immediately to the Compliance Officer or Human Resources. All reports will be taken seriously and investigated thoroughly and discreetly. Retaliation against whistleblowers is strictly prohibited.

Disciplinary actions for violations may include warnings, training, suspension, termination, and legal action, depending on the nature and severity of the offense.

8. No Retaliation Policy

Wounds Plus will not tolerate retaliation against individuals who report concerns in good faith. Employees are encouraged to raise ethical or legal concerns without fear of reprisal. Retaliatory behavior will be treated as a serious violation of this Code and subject to disciplinary action.

9. Accountability

Every employee, officer, and director is responsible for understanding and adhering to the Code. Violations of the Code may also be violations of law and subject to legal penalties. Wounds Plus leadership will regularly review adherence and take corrective action as needed.

10. Annual Acknowledgement

All team members must review this Code annually and sign an acknowledgment affirming their understanding and commitment to compliance. This process reinforces our shared responsibility to uphold the values of Wounds Plus.

11. Waivers

Any waiver of this Code for executive officers or directors must be approved by the Board of Directors. Waivers for other employees may only be granted by the Chief Compliance Officer and will be documented in accordance with company policy.