BUSINESS CONDUCT, COMPLIANCE AND ETHICS PROGRAM

Letter from Novation President Jody Hatcher

As the nation’s leading contracting services company and an affiliate of VHA Inc., University HealthSystem Consortium (UHC) and Provista, LLC (collectively, the Alliances), Novation is committed to safeguarding its reputation as an ethically responsible and transparent company.

To achieve this goal, Novation has a comprehensive Business Conduct, Compliance and Ethics Program. The Program enriches our company by creating a foundation for our business performance, providing clear guidance to our employees and serving as a roadmap to reduce our level of risk.

Standards of Business Conduct are crucial to building and maintaining the trust of our stakeholders – our Alliances, Alliance members, suppliers, employees and governmental authorities. These core principles guide the professionalism that Novation strives for in its business relationships and in the personal integrity we expect of our employees.

Each employee of Novation has a critical role in maintaining our corporate integrity and is responsible for fostering Novation’s good name. Our commitment to ethical and transparent business practices must be demonstrated in every action. Novation expects that every employee will comply with the principles and guidelines laid out in these Standards of Business Conduct.

This document clearly defines the expected standards of behavior, answers questions about the appropriateness of our conduct and explains how to report possible violations of law or ethical principles within Novation.

I appreciate that every day we confront issues that are complex and difficult. While we are not all legal experts, it is my expectation that we will all use good judgment and common sense, and seek advice when we are uncertain. Remember, these Standards of Business Conduct are not just pieces of paper; they represent the foundation for our daily business practices.

On behalf of the Board of Directors and the senior leadership team, I want to thank you for your commitment to and support of Novation.

Sincerely,
Jody Hatcher
President and CEO