BUSINESS CONDUCT, COMPLIANCE AND ETHICS PROGRAM

Reporting Violations

Compliance Hotline

Novation has established a compliance hotline that allows concerned parties to confidentially report compliance-related issues via Web-based reporting or by calling a toll-free number. The services associated with the hotline are provided by EthicsPoint an independent third party that provides services to a wide array of customers within and outside the health care market.

To ensure that no employee or other concerned party is unable to or discouraged from filing a report, Novation has elected to have a toll-free number — (877) 220-1615 — available for reporting, as well as a customized Web reporting system (www.EthicsPoint.com) to provide an additional vehicle for reports to be filed.

All reports filed through the hotline are managed by EthicsPoint to ensure independence in reporting. Reporting parties have the option to remain anonymous if they so choose. The Web site will contain information about the Business Conduct, Compliance and Ethics Program. Such information shall include the Standards of Business Conduct and an overview of the Business Conduct, Compliance and Ethics Program.

In addition to employees, suppliers who wish to file a formal grievance as is it relates to the bid process are also encouraged to use the hotline. Information about the hotline will be posted internally for employees to reference as needed and externally as deemed appropriate. Additional materials will be provided to employees during their orientation and compliance training.

Duty to Come Forward

Novation is committed to open communication with employees as it relates to ethical and legal issues. All employees are expected to report any known potential legal or ethical wrongdoing to their supervisor, management, or the Legal or Compliance Departments. Employees are encouraged to ask questions if they have any concerns about compliance with law, these Standards or applicable Policies and Procedures. Remaining silent about an issue prevents Novation from addressing the situation and may potentially subject the company to liability.

Investigation of Complaints

Novation is committed to thoroughly investigating every inquiry and complaint an employee makes. Each complaint will be fully investigated on the merits and, depending on the results of the investigation, appropriate action will be taken.

Knowing When to Raise Issues

Every Novation employee is obligated to bring to the attention of management any instance in which he or she is aware of conduct that violates these Standards, Novation’s Policies and Procedures or applicable laws and regulations. Further, employees should also raise with management any concerns they may have as to whether proper procedures are being followed, even though they are not certain whether legal or ethical standards are being violated. It is also important that employees make management aware whenever they believe adequate resources or training are not being provided so as to enable employees to comply with legal standards applicable to Novation.

Non-Retaliation

Novation prohibits harassment of, or retaliation against, any employee or other person who, in good faith, reports a known or suspected violation of law, these Standards or company Policies and Procedures.

Subject to Novation’s obligations under applicable laws and regulations and its need to investigate the issue, Novation takes every step possible to ensure the confidentiality of its employees. Although coming forward will not immunize an employee from the consequences of his or her own misconduct, the employee’s good-faith reporting of an incident will be protected.

Any employee who engages in malicious or spurious reporting of violations will be subject to discipline, up to and including termination of employment.

Any supervisor who has engaged in, or condoned, any form of retaliation against an individual in response to a good-faith report of a violation or suspected violation will be subject to discipline, up to and including termination of employment.

Procedures for Raising Issues

Employees are encouraged to raise issues or concerns with their immediate supervisors. If, for any reason, an employee is uncomfortable approaching his or her supervisor, the employee may also bring issues forward by speaking with:

• A member of the Human Resources Department
• Any member of the senior management team of Novation
• Any member of the Compliance or Legal Departments

Alternatively, employees, members, suppliers and other interested parties may submit concerns through Novation’s (1) Compliance Department Web site, or (2) toll-free compliance hotline, (877) 220-1615, each of which are available 24 hours a day, seven days a week.