Compliance Hotline

The Company is committed to the highest possible standards of ethical, moral, and legal business conduct. In conjunction with this commitment and our commitment to open communication, this policy aims to provide another avenue for employees to raise concerns and reassurance that they will be protected from retaliation in any form for raising awareness of issues in good faith. However, if an employee feels that their anonymity is not required, then they should follow our existing grievance procedure.

Retaliation

Retaliation in any form against individuals submitting hotline reports will not be tolerated.

Confidentiality

The policy is intended to cover serious concerns that could have a large impact on the facility, such as actions that
• may lead to incorrect financial reporting;
• are unlawful;
• are not in line with company policy, including standards of conduct and professionalism outlined in the Employee Handbook; or
• otherwise amount to serious improper conduct.

Regular business matters that do not require anonymity should be directed to the employee’s supervisor, the Administrator, or to the Resource Center.

Every effort will be made to protect the reporter’s identity by our hotline vendor. Please note that the information provided in a hotline report may be the basis of an internal and/or external investigation by the facility into the issue being reported. It is possible that as a result of the information provided in a report, the reporter’s identity may become known to us during the course of our investigation.

Anonymous Allegations

The policy allows employees to remain anonymous at their option. Concerns expressed anonymously will be investigated, but consideration will be given to
• the seriousness of the issue raised;
• the credibility of the concern; and
• the likelihood of confirming the allegation from attributable sources.

Malicious Allegations

Malicious allegations may result in disciplinary action.

Reporting

The reporting procedure is intended to be used for serious and sensitive issues. Serious concerns relating to financial reporting or unethical or illegal conduct should be reported in one of the following ways:
• Website: www.lighthouse-services.com/aspenskilledhealth
• English-speaking USA and Canada: (833) 650-0004 (not available from Mexico)
• Spanish-speaking Mexico: (001) 800-681-5340
• E-mail: reports@lighthouse-services.com (must include company name with report)
• Fax alternative for written documents: (215) 689-3885 (must include company name with report)

Reporters to the hotline will have the ability to remain anonymous if they choose. Please note that the information provided by you may be the basis of an internal and/or external investigation into the issue you are reporting, and your anonymity will be protected to the extent possible by law. However, your identity may become known during the course of the investigation because of the information you have provided.

Reports are submitted by Lighthouse to the facility or its designee and may or may not be investigated at the facility’s sole discretion.

Employment-related concerns should continue to be reported through your normal channels such as your supervisor, the facility Administrator, a Human Resources representative, any member of management, the Vice President of Compliance, or the Resource Center at (949) 347-7100.

Timing

The earlier a concern is expressed, the easier it is for us to take action.

Evidence

Although you are not expected to prove the truth of an allegation, the employee submitting a report needs to demonstrate in their hotline report that there are sufficient grounds for concern.

Responding to a Report

The action taken will depend on the nature of the concern. The Administrator and the Resource Center receive a copy of each report and follow-up reports on actions taken by the facility.

Initial Inquiries

Initial inquiries will be made to determine whether an investigation is appropriate and the form that it should take. Some concerns may be resolved by agreed-upon action without the need for an investigation.