ETHICS & COMPLIANCE STATEMENT

At Optimal DME, we are devoted to delivering superior quality and integrity across all our operations. Our unwavering commitment to ethical practices and compliance with applicable laws is foundational to our mission, as we seek to maintain the highest standards in our engagements with patients, payors, employees, and the broader community. Optimal DME operates under two key principles:

PATIENT CARE AND COMPLIANCE WITH ALL LAWS
(OUR “COMPLIANCE MANDATE”).

Optimal DME strictly adheres to a zero-tolerance policy concerning any violations of our Compliance Mandate. All employees, contractors, and affiliated parties are expected to maintain the highest standards of patient care while fully complying with all relevant laws and regulations. We categorically refuse to engage in any unethical or illegal business practices. Our compliance program is designed around seven critical components: (1) established standards of conduct and policies that promote our compliance commitment; (2) a Compliance Officer overseeing the program; (3) comprehensive compliance training for all new hires, supplemented with annual updates; (4) processes for reporting concerns and complaints without fear of retaliation; (5) prompt responses to allegations of misconduct, including the development of corrective action plans when necessary; (6) ongoing auditing and monitoring to identify potential risks; and (7) thorough investigation and resolution of identified systemic issues, ensuring no sanctioned individuals are employed.

To support our Compliance Mandate, we have implemented a comprehensive Code of Ethics and Business Conduct (“Code”), applicable to all employees, contractors, suppliers, and officers. The Code serves as a guide for complying with laws, regulations, and company policies. We routinely communicate about the Code to ensure all team members are familiar and committed, requiring annual certification of adherence from every employee.

Our Code also incorporates anti-retaliation provisions to protect individuals who report concerns. We advocate for open communication and are committed to safeguarding those who come forward with issues in good faith. Any retaliation against individuals participating in the reporting process will be met with serious consequences.

Optimal DME offers ongoing, role-specific training designed for various employee functions. This training—available in both in-person and online formats—covers crucial compliance topics, including anti-kickback laws, false claims, Stark Law, conflicts of interest, privacy protections, anti-discrimination, and guidelines for gifts and hospitality. We monitor training completion and require periodic certifications from management-level employees regarding compliance with our policies.

Recognizing the importance of robust risk oversight, Optimal DME is dedicated to nurturing a culture of risk management, ensuring we address a spectrum of risks including competitive, legal, regulatory, operational, and financial.

In summary, our Compliance Program exemplifies Optimal DME’s commitment to: (1) providing education, policies, and tools for the best patient care and legal compliance; (2) conducting thorough investigations and taking action in response to any indications of misconduct; (3) actively monitoring company activities through internal audits to assess risk; and (4) maintaining a proactive approach to compliance that reinforces our Compliance Mandate. We are dedicated to delivering the highest standards of patient care and ensuring strict adherence to ethical practices.